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The Post Office Horizon IT Inquiry
Tuesday, 18 June 2024
(9.45 am)
MRBEER: Good morning, sir, can you see and hear us?
SIR WYN WILLIAMS: Yes, I can, thank you.
MR BEER: May I call lan Henderson, please.
IAN RUTHERFORD HENDERSON (sworn)
Questioned by MR BEER
MR BEER: Good morning, Mr Henderson.
A. Good morning, Mr Beer.
Q. You know that my name is Jason Beer and I ask questions
‘on behalf of the Inquiry can you give us your full name
please?
A. Myname is lan Rutherford Henderson.
Q. Thank you for giving evidence today and for previously
providing a long and detailed witness statement; it's
60 pages long and is dated 20 May. The URN is
WITNO00420100. Can we turn, please, to page 60, of that
witness statement.
A. Yes.
Q. Is that your signature?
A. Yes, itis.
Q. Can we just go back to page 59, and paragraph 163, which
is at the bottom.
A. Yes.
Q. You say:
1
A. Correct.
Q. In terms of your prior career before Second Sight, you
were Manager of the Investigations Division at Lloyd's
of London, with responsibility for investigating fraud
worldwide; is that correct?
A. Correct.
Q. You were subsequently Head of Investigations at what was
then the country's largest financial services regulator?
A. That's correct as well.
Q. You worked on a part-time basis for the Criminal Cases
Review Commission, the CCRC, for four years; is that
right?
A. Yes.
Q. You subsequently joined Second Sight Support Services
Limited and Second Sight Investigations Limited; is that
right?
A. Yes, itis.
Q. In broad terms, in the year 2020, what did those --
sorry, 2012 -- what did those companies do?
A. Avariety of professional services. My appointment was
as a contractor, consultant, and I was assisting Ron
Warmington in the -- in various, sort of, projects that
the company was involved with.
Q. Was one of those projects the Horizon project for the
Post Office?
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"In the course of our work, I increasingly felt that
your overriding duty was, in a phrase attributed to Alan
Bates, to help ‘the skint little people’ who didn't have
a voice and who had been so badly treated by ‘the Post
Office’,
Is there an amendment that you wish to make to that
paragraph?
Yes, there is.
Can you tell us what it is?
I'm delighted to say that Sir Alan Bates has recently
and I have not updated my witness statement, so I'd like
to change Alan Bates to Sir Alan Bates.
Thank you. If we go over the page, please, to page 60.
You've told us that that's your signature. Are the
contents of the witness statement true to the best of
your knowledge and belief?
Yes, they are.
Thank you very much. That can be put to one side. In
terms of your background, I'm going to take this shortly
Mr Henderson, if I may. You served in the British Army
for nine years and then, in 1980, qualified as
a chartered accountant; is that right?
Yes, it is.
You're now, I think, a Fellow of the Institute of
Chartered Accountants of England and Wales?
2
Yes, it was.
I think in 2012, you were a member of the International
Society of Forensic Computer Examiners --
That's correct as well.
-- and a certified computer examiner?
Correct.
As you tell us in your witness statement, they're all
listed in your witness statement, you have provided
written and oral evidence in a large number of civil and
criminal cases and regulatory cases as an expert
witness?
Correct.
Thank you. Can I turn, then, to the appointment of
Second Sight. I think it's right that Second Sight was
approached by the Post Office in mid-2012 with
a business proposal to undertake some investigatory work
for it; is that right?
Yes.
In your witness statement -- no need to turn it up --
it's paragraph 22, you state that:
"Ron Warmington prepared a business proposal dated
1 June 2012 and Susan Crichton produced a document
describing the objectives of the investigation.”
Yes.
Can we look at that document, please. It's POLO0096575,
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and it'll come up on the screen for you.
Thank you.
You'll see from the top that this from Susan Crichton to
Alice and Paula Vennells and it's dated 6 June 2012. Is
this a document you would have seen at the time or is it
an internal Post Office document?
I'm pretty sure this is an internal Post Office document
and we wouldn't have seen it but it does reflect the
proposal prepared by Ron Warmington.
It states in the first paragraph that:
"Post Office has decided to conduct an independent
review of a number of closed and possibly some open
fraud and theft cases."
If we scroll down, please, under "Objectives &
Scope":
"The Post Office has instructed an independent third
party organisation, Second Sight Limited to provide
a proposal to conduct a review which would include the
following tasks:
"[1] Select a representative sample of cases that
have led to prosecutions/court-appointed [resolutions].
The sample needs to cover cases [and they're listed].
"[2] Carefully review all company-held documentation
[et cetera].
"[3] Interview company investigators ...
You were essentially being interviewed for the position
of investigators of Horizon, correct --
Yes.
-- ie the MPs wanted to see whether you were suitably
skilled and independently minded?
Correct.
If we scroll down, please, and just go over the page
please, if you look five paragraphs from the bottom --
have you got that? It'll be marked for us. "IH",
that's a reference to you, I think?
Yes.
"[lan Henderson] said that a systems-based approach
(code review etc) would take over 6 months and cost over
£500,000. This [is] further complicated by the fact
that Horizon is now in a new iteration, and is [the] old
code available?"
Is that an accurate record of what you said or the
kind of things that you said?
Yes, I think so. I mean, we were not qualified to do
a code-level review but we wanted the MPs to be aware
that that was always an option. However, we felt that
the costs were probably disproportionate and wouldn't
necessarily represent value for money.
You say you weren't qualified to do a code review
because you were, essentially, forensic accountants,
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"[4] Review defence submissions focusing on evidence
of innocence ..."
If we keep scrolling down, please, the penultimate
bullet point provides that Second Sight would be
instructed to:
"Study and selectively test the ‘Horizon’ system in
order to find any ‘Black Hole’, Program Bug; etc that
might have caused mysterious shortages."
So was it correct that, at this point in time, and
we're here at 6 June, envisaged that the investigation
carried out by Second Sight would involve to study and
selectively test the system itself?
My understanding was that we'd look at inputs and
outputs. We'd look at how the Horizon system actually
worked in practice, we would not be doing a technical
code review of the software.
see. So you wouldn't have read this, if you'd seen it
at the time, as referring or inferring to a code
examination?
Correct.
Can we move on, please, to JARB0000022. This is a month
later, on 4 July, and it's a meeting between you,
Mr Warmington and some MPs. I suspect you remember
attending that meeting?
Yes, I do.
rather than --
Software engineers.
- software engineers, correct?
Yes.
There was the additional point about whether the code
from Legacy Horizon was, in fact, available for review;
is that right?
Yes, I mean, Horizon was constantly changing and, as we
got into this, we realised that, in fact, throughout the
country, there were various versions of Horizon in
operation, which would make any code review virtually
impossible.
Can we turn, then, to POL00180832, please, and scroll
down. Sorry, if we just scroll up, please, to the top
of the page, you'll see this is an email of 4 July, so
I think the same day as that meeting that we've just
looked at, from Mr Warmington to Susan Crichton, Simon
Baker and copied to you. It's about "Today's Meeting";
do you see that?
Yes.
If we go to page 2, please, and about eight lines down,
you'll see the words "We carried", that will be marked
for you. Mr Warmington said:
"We carried out a reality check here, saying that
we'd NOT been asked to dig deep into Horizon looking for
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deeply-embedded bugs at the code level ... indeed, we'd
not recommend that course of action (certainly not at
this stage)."
Again, does that accurately reflect what went on in
the meeting between you and the MPs?
Yes, it does.
It continues:
"Rather, we trust our instincts and experience that
a deep review of a sample of cases, focusing not on
whether there had been False Accounting but on
IDENTIFYING THE UNDERLYING ROOT CAUSE OF THE
DISCREPANCY, would without doubt help us to formulate
a recommendation as to whether some such deep digging
would, later, be worthwhile."
Again, does that accurately reflect, firstly, what
you told the MPs?
Yes. I mean, with one qualification: I mean, false
accounting was a potentially relevant issue, so we
wouldn't have ignored that, but we were concerned at
identifying the best evidence without doing a code
review, and that was going to be looking at a sample of
cases.
So drawing these threads together, it's right that you
didn't recommend, and in fact recommended against,
a systems-based or code-based review at this time; is
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to work."
In describing your appointment as not being
straightforward, are you there referring to the things
that follow in that paragraph; are they the reasons why
it wasn't straightforward?
I think the main reason -- and in my experience, it was
unique -- we work being appointed to do a task by one
group of people but it was actually Post Office who was
going to be paying the bill but didn't have any direct
control over the scope of work that we were doing or the
length of time it was going to take. That, as I say,
was an unusual situation.
I'm going to come to that in a second.
Okay.
What impression did you gain, if any, from the Post
Office, as to why the Post Office appointed Second Sight
over other forensic accountants?
I don't know. I mean, I suspect it was because we were
relatively cheap, compared with the big professional
firms, but, of course, they had to be satisfied that we
would do a competent job, which I believe we
demonstrated, both at the time and subsequently.
From the outset, were you and Second Sight alive to the
possibility that the Post Office may have had
an ulterior motive for commissioning this investigation
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that right?
Yes, it is.
Did there come a time later in your work that you ever
recommended or Second Sight ever recommended
a systems-based or code-based review --
We were always open to that possibility. I don't think
we ever made a formal recommendation that it should
happen. I mean, after the termination of our
appointment, I'm aware that some sort of code review was
considered but it was possibly a bit inconclusive.
Considered by who?
By Post Office.
Do you know why that wasn't taken forwards?
No, I don't.
Thank you. That can come down. Can we go back to your
witness statement, please, and if we do pull this up on
the screen it's paragraph 23, which is on page 8. You
say in paragraph 23, if we scroll down, please:
“Our appointment was not straightforward. Alan
Bates [as he then was] and the Justice for
Subpostmasters Alliance (JFSA) were concerned that we
would not be truly independent and would say whatever
Post Office wanted us to say. Post Office needed to be
assured that we had the necessary skills for the task.
MPs did not want to support something that wasn't going
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or this review?
Well, it was clear throughout that Post Office didn't
want to commission a review and it was only through the
efforts of people like the MPs, James Arbuthnot in
particular, that they were forced to agree to it. I do
recall hearing -- I don't know whether this is true --
that Post Office was told, if they didn't agree to it,
it was going to be raised in the House and a review
would be forced upon them, so it would be better to at
least agree to it in the way that they subsequently did,
even though somewhat reluctantly.
That can come down. Thank you.
You tell us in your witness statement -- this is
picking up a point that you made a moment ago -- that
you came deeply to regret that, although Second Sight's
clients comprised the MPs and the JFSA, as well as the
Post Office, the contract was between Second Sight and
the Post Office.
Um --
What was the problem there?
I'm not sure the contract was between Second Sight and
the Post Office. I mean, I always regarded that our
terms of reference were set by the MPs. However, we
were being -- our professional fees were being paid by
the Post Office and we had to sign confidentiality
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agreements and non-disclosure agreements with the Post
Office. So that element was a contract but I regarded
throughout, and still do, that our ultimate duty lay on
behalf of the MPs and what they were asking us to do.
Did you, in fact, sign a contract with the Post Office?
We signed various bits of paper that probably did
represent a contract but they were principally dealing
with non-disclosure and confidentiality issues.
Was there a contract between Second Sight and the Post
Office that set the terms of reference for the
investigation?
Yes, I believe there was and, of course, it changed over
time. I think Post Office somewhere referred to Job 1
and Job 2, and so on, and certainly, once we got into
the Mediation Scheme, that was a separate set of work.
So it was the fact that you were appointed by MPs at the
request of subpostmasters but your professional fees
were paid by the Post Office -- was that the concern?
It wasn't so much a concern. I recognised that was
a very unusual situation and had to be handled quite
sensitively.
Did it, in fact, cause problems subsequently?
Certainly, the issues of non-disclosure,
confidentiality, and so on, were raised by Post Office
subsequently. They were very concerned about us
13
to consider and to advise on whether there were
any systemic issues and/or concerns with the 'Horizon'
system, including training and support processes, giving
evidence and reasons for the conclusions reached."
Just stopping there, "to consider and to advise on
whether there were any systemic issues and/or concerns.
with the ‘Horizon’ system". It's right, therefore, that
the issue of a consideration of whether there were
systemic issues was part of your terms of reference from
the very start; is that right?
Yes.
Looking back now, would you consider that that remit was
too broad?
I don't know whether it was too broad in itself, it was
certainly widely misunderstood and I regret the fact
that the word "systemic" had ever been used in this
context. "Systemic", of course, means system-wide and
the main focus of our review was going to be on
individual cases not a code review, not an in-depth
review of the entire system. So there was some
difficulty with the word or term "systemic", which,
I think, was first used by Susan Crichton, General
Counsel for Post Office, rather than us.
You said that the term "systemic" was widely
misunderstood; misunderstood, in your view, by who?
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disclosing, you know, confidential information without
their authority and they still are.
To this day?
To this day, as far as I'm aware.
You tell us in your witness statement that, over the
course of three years, Second Sight investigated about
140 individual cases?
Yes.
Did those cases include cases in Scotland and Northern
Ireland as well as those in England and Wales?
No, they were principally England and Wales.
Was that deliberate or were your doors open to the
referral of any cases?
I think it reflected the geographical sort of structure
within Post Office and also reflected the way that cases
were referred to MPs. There was a small group of MPs
who exclusively, I think, were representing English
constituencies, it just so happened that we didn't get
any cases from either Northern Ireland or Scotland at
that stage.
Thank you. Can we turn to the remit of the
investigation and you refer to this in your witness
statement. It's page 17, paragraph 56, if that can be
brought up, please. The remit of the Inquiry, you say,
was described as:
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Well, again, no criticism of Sir Alan Bates but I was
using the Oxford English Dictionary of systemic, in
‘other words of the whole system, system wide. Alan,
I think, saw "systemic" as caused by the system, which
is a much narrower definition and it certainly had the
potential to cause confusion.
At this point, at the beginning of the investigation,
rather than at the end, was there any attempt made to
define what "systemic" meant?
Not that I can recall.
What was the Post Office's attitude to the use of the
word "systemic" in your dealings with it?
I don't recall having any detailed sort of discussion,
so it’s not something that I really considered in any
detail. I just felt it was an unfortunate sort of term
that -- not one that we had adopted.
You do use it in your Interim Report of 8 July 2013 --
Yes.
-- albeit in brackets, after the word, you say
"system-wide".
Yes.
Was the effect of the use of word "systemic" or the
phrase “systemic issues", both here and subsequently, to
allow the focus to be on the fact that there were no
system-wide issues with Horizon, thus diverting
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attention or focus away from bugs, errors and defects
which did exist?
I think that was how it was used by Post Office. I do
recall various press releases, and so on, that trumpeted
the fact that Post Office claimed that we had said that
we had found no systemic or system-wide issues with the
Horizon system, which was, of course, not what we said
at all.
You tell us in your witness statement -- I'm moving
forwards now, if we go to page 26 and paragraph 78,
we're going to come back to the detail in a moment but
I'm just looking at the use of language at the moment --
you say that your overall conclusion at this stage, July
"13 -- that's the month of publication of the Interim
Report -- was that:
"... Post Office Horizon was not the robust,
error-free system claimed by [Post Office]. I was also
concerned about the potential loss of integrity caused
by working practices within Fujitsu, such as remote
access without the knowledge or consent of individual
subpostmasters. I was beginning to form the view that
no prosecution relying on Horizon evidence could be
safe."
Do you make it clear, or did Second Sight make it
clear, at the time of publication of the Interim Report,
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Legal.
So you were physically in the office. Which office was
this?
This was in the Old Street office, their previous
headquarters.
Was this is an open-plan office?
The main office area was open plan. Some of the senior
executives did have their own offices but I was sitting
in the open plan area and, therefore, could see what was.
going on, had access to case files, and so on.
I think you just said that you sat near to or closest to
Jarnail Singh; is that right?
Yes, it is.
How were files stored in the Legal Department, so far as.
you could see?
Somewhat shambolically and haphazardly. I think
I described it as a rather old-fashioned office, where
the focus was on paper files rather than electronic.
Whilst they -- you know, they obviously used IT
technology, they tended to print everything out and put
a paper copy on a file and it was the paper files that
were the master copies. When I first started work in
the Legal Department, I seem to remember there was only
a very small number of files available and this
reflected the somewhat decentralised sort of nature of
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that you or Second Sight were forming the view that no
prosecution relying on Horizon evidence could be safe?
Bear in mind it was an Interim Report and that any
conclusions were preliminary and needed to be -- you
know, further work needed to be performed. That was
certainly the view that I had formed at that stage.
Whether we expressed that as clearly as perhaps we
should have done I think is arguable.
You've spoken about the messaging of the Post Office and
its reuse of the phrase "no systemic issues". Were you
frustrated, at the point of publication, with that
messaging?
I felt it was probably somewhat misleading. It was not
a phrase that we would have chosen, even though we did
adopt it and use it in our report. It was widely
misunderstood and was not clear communication.
Thank you. That can come down.
Can I go back to the beginning, then, to the start
of your work in mid-2012 with the Post Office. I think
it's right that you worked physically close to the Post
Office Legal team during your investigation?
Yes. I spent most of my time actually based in the
Legal Department, which was an open-plan office, sitting
next to Jarnail Singh and immediately outside Susan
Crichton's office, who was the Post Office Head of
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the way that they operated.
Bear in mind also that they had only recently
divested from Royal Mail Group and it was a subset of
much larger Legal Department of Royal Mail Group that
travelled with the Post Office part of the organisation.
So the department was relatively small. They had
a policy of outsourcing many of the prosecutions to
regional firms of solicitors who maintained their own
files so that, when I started work, there was only about
10 or 12 legal case files available to me.
You say in your witness statement -- no need to turn it
up, it's paragraph 36 -- you were surprised at the small
size of the Legal Department within Post Office?
Yes. Now --
Why were you surprised?
Well, bear in mind the size of the Post Office, you
know, at that time probably 11,500 branches; we now know
over 700 prosecutions. The visibility of the Legal
Department, that I could see anyway -- and it might have
been, you know, the tip of the iceberg, I just don't
know -- but I only met probably a maximum of about ten
lawyers and that seemed to me to be relatively small,
bearing in mind the size and the importance of the
organisation.
You also say in that paragraph that you noticed the
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difficulties that the Legal Department had in getting
case files under control. What did you mean by that,
please?
Again, I'm probably referring to the decentralised way
of operating. The fact that, you know, if there was
a prosecution in the north of England that would be
handled sort of locally and the file would probably be
held locally, and it was only when I asked for all of
the relevant prosecution files to be moved to a central
location that it actually happened.
You tell us in your witness statement, at paragraphs 32
and 36, that you noted at the time that Susan Crichton
relied on Jarnail Singh for criminal law matters; is
that right?
Yes, itis.
Did you witness that?
Yes. I mean, I had conversations with Susan. I had met
Susan Crichton in her previous role when she was working
for -- I think it was General Electric and I knew her as
a civil or commercial lawyer not a criminal practitioner
and, therefore, she'd have to rely very heavily on
a specialist criminal practitioner for advice on
prosecutions and that was Jarnail Singh.
He was your main day-to-day contact within the Post
Office Legal Department; is that right?
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we published our report."
Then this:
"I subsequently noticed that a copy of the ‘Receipts
and Payments Mismatch Problem’ was included [in] the
hard copy file relating to the Seema Misra prosecution.
In 2024, as a result of seeing the evidence of Simon
Clarke to the Inquiry, I realised that this document was
not disclosed at her trial and had been subject to
a [Pll] certificate exemption.”
Breaking those things down first, if we go to the
foot of the page, page 25, first, last sentence, you
say:
"I subsequently noticed that a copy of [and then you
describe something] was in the hard copy file ..."
"Subsequently", does that mean after June 20137
I can't remember precisely when I first became aware of
that. It was certainly disclosed to us by someone
called Simon Baker who worked for Post Office. But it
was when I was listening to the evidence of Simon Clarke
to this Inquiry that I realised that it had not been
disclosed to Seema Misra.
So is it the case that you can't remember now when you
saw that it was included in the hard copy file?
I can't remember precisely, no.
Okay. In what circumstances did you come to see it on
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As far as prosecution matters were concerned, yes.
As your main day-to-day contact, did you form a view of
Mr Singh?
Yes, I did.
What was that?
He didn't strike me as a lawyer. He struck me more as
an administrator that was dealing with farming out of
potential cases, dealing with administrative matters,
chasing progress by third-party solicitors around the
country. His level of knowledge of prosecutions
actually seemed, in my mind, to be quite limited. I was
having to do, you know, my homework and look at the Code
of Conduct for Crown Prosecutors, for example. I was
putting technical legal questions to him and he often
didn't -- wasn't able to answer me, which found
surprising.
How long did you spend embedded in the Legal Department?
I can't recall precisely but it was a number of weeks.
Can we turn up, please, page 25 of your witness
statement. Page 25, at the foot of the page, please,
paragraph 77. Again, we're moving forwards here but
I want to pick up something that you say. You say:
"The 'Receipts and Payments Mismatch Problem’ and
‘Local Suspense Account Problem’ were disclosed to us by
[the Post Office] in June 2013, just a few days before
22
the hard copy file?
I think it was when I was in the Legal Department at
Post Office and we were looking at -- I mean, the two
files I recall in particular were Jo Hamilton and Seema
Misra. Out of the relatively small number of files that
were made available to us, those were certainly the most
important.
Just stopping there, Mr Henderson, so you saw the file
in Old Street --
Yes.
-- in the Legal Department --
Yes.
-- and a document that you describe there was on the
file? Were the files bound in any way?
They were the old-fashioned spring binders where you
could file individual sort of documents. Do you
remember those spring things that used to go through
punched holes?
I'm too young --
(The witness laughed)
- for that. Do you mean a paper file?
Itwas a hard copy paper file, yes. Not a ring binder.
There were two sprigs that came out of it, maybe
plastic --
Yes.
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-- or metal, and you would add documents to it --
Yes.
-- and then put a clip over the top of it --
Well done, yes.
-- is that right?
Yes.
Okay. Was this bound, the document you're talking
about, or can't you remember?
No, it was a working file and, again, the working style
of Post Office was to produce individual documents,
letters, memorandum, and file them on these hard copy
files.
I see. Was there a filing cabinet within the Legal
Department for these files to be kept?
I assume so. I mean, they were produced to me -- in
terms of files, I had a desk about this size and I do
recall that I had, you know, about ten hard copy files
piled up on that desk and I was working through those.
In terms of the document that you say that you saw, you
say that "a copy of the ‘Receipts and Payments Mismatch
Problem’ was included". Are you referring there to the
not of the meeting about the receipts and payments
mismatch problem?
The document I recall was one, I think, that I discussed
with Gareth Jenkins and it was a filenote prepared by
25
I just it get the sequencing right with you,
Mr Henderson. I'm just reading your paragraph 77, so
the bottom of page 25. You say:
"The ‘Receipts and Payments Mismatch Problem’ and
‘Local Suspense ... Problem’ were disclosed to us by POL
in June 2013, just a few days before we published our
Interim Report.”
But then you say:
"I subsequently noticed that a copy of the ‘Receipts
[et cetera] was included in the hard copy file relating
to the Seema Misra prosecution."
So my reading of that was that you were told about
the mismatch problem shortly before your report was
disclosed and that, some time later, though you didn't
specify precisely when, you actually saw a copy of the
document. My impression from your evidence this morning
is that you say you saw the document when you were
embedded in Old Street, which, of course, as
I understand it, would have been before June 2013. Now,
am I making a mountain out of a molehill, or what,
Mr Henderson?
Sir, you're not and I think the missing link here is
that, as part of my research prior to giving evidence
today, I revisited the file listing that I think I have
referred to in my witness statement, that was a list of
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him, I think it was dated 2010, so it was, you know,
well before I had access to the files.
Q. Okay, so it was a Gareth Jenkins authored document?
That's my recollection.
Q. Okay, we've got that. We can look at that. It's
September, 29 September 2010. That's the document
you're referring to; is that right?
A. Yes.
Q. You say, in the last sentence there, that that had been
the subject of a Public Interest Immunity certificate
exemption. From whom did you learn that?
A. The Inquiry and the evidence of Simon Clarke.
Q. Inthe Inquiry, we haven't called any evidence about
a Pll application in the Misra case about that document.
A. Right, well, I may have misunderstood Simon's evidence
but I thought he said it had not been disclosed to Seema
Misra because of a Pll immunity.
Q. Okay but that sentence is based on what you've
subsequently heard --
>
A. Yes.
Q. -- in the Inquiry, is it, rather than something at the
time?
A. Correct.
Q. Thank you very much. That can come down.
‘SIR WYN WILLIAMS: Before we leave it there, Mr Beer, can
26
some 34,000 documents that I had held at one point and
had returned to Post Office. When I checked that file
listing, which was provided both to the Inquiry and to
the Metropolitan Police, I could see that there was
reference to this receipts and payments mismatch
document.
So it was definitely included in the documents that
we did hold, at some point previously, but then returned
to the Post Office, in 2015.
SIR WYN WILLIAMS: Yes, sure. I'm not for a minute doubting
that you saw these documents; I simply wanted to get the
sequence correct, if you see what I mean. So was it you
saw the document and then some time later, in June 2013,
just before the publication of your Interim Report, POL
formally disclosed it to you, or is it that they
formally disclosed it to you and then you actually saw
it in the file? I'm not asking you for dates or
anything, just the sequence.
A. I can't be precise about the sequence. I do recall
seeing it before we finalised our Interim Report.
SIR WYN WILLIAMS: All right, fine. Thank you.
MR BEER: Thank you. That can come down.
You mention that you focused on two specific files,
the other one being Jo Hamilton; is that right?
A. Yes.
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Was that a focus of yours in the course of the initial
investigation?
Yes. It was. I mean, purely by happenchance, I mean
the first file that I came across when I was in the Post
Office Legal Department was Jo Hamilton's file, so that
was the first file that I looked at in any detail.
I want to -- again, I'm taking things out of order --
turn to an issue involving Josephine Hamilton's case
that arose in the Mediation Scheme. So this is much
later. This is post-8 July 2013. Indeed, it's into --
2014.
-- 2014 --
Yes.
-- and, indeed, '15 and just use it as an example or
an exploration of the kind of issues that you faced.
Okay.
In the Mediation Scheme, did parts of the process
include the Post Office sending a report to Second Sight
called the Post Office Investigation Report?
The POIR, yes.
Then Second Sight would create a Case Review Report,
a CRR; is that right?
Yes, it is.
Then that would go to the applicant, the subpostmaster,
to the Post Office and to the Working Group; is that
29
the applicant's complaints; the Post Office's
investigations into them; and then the Post Office's
conclusion about them?
This is fairly typical of many of the reports produced
by Post Office. I mean, they often said errors made at
the counter was, you know, the explanation for any
discrepancy. I think I felt that they -- this
demonstrated a lack of in-depth investigation and didn't
match the findings on the file that I subsequently
reviewed.
If we turn to page 8, please, and if we scroll down, so
we can see all of that -- thank you -- is there a list
of documents that were provided to Second Sight?
Yes.
Was, again, this the common approach, that there would
be a list of documents that the Post Office would
provide along with this report, the POIR, to Second
Sight?
Yes, and if you look at the left-hand column, it's all
pre-fixed by M035, which was the case number, and then
the description of the document. So it was following
a consistent pattern across many of the cases that we
were looking at.
You'll see that they're sequentially numbered M035,
underscore something and then ending in 01, 02, 03,
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right?
Yes.
Can we look, please, at the Post Office Investigation
Report in Ms Hamilton's case. POL00034551. We will see
that it's headed at the top "Initial Complaint Review
and Mediation Scheme, Post Office Investigation Report”.
The applicant's name on the left-hand side "Josephine
Hamilton" and then the case number M035. Was each
applicant given a unique reference number like that?
Yes, they were.
Then you'll see that there's an executive summary and
then a narrative account, if we scroll down, of the Post
Office's views and the investigations that it had
conducted. Keep scrolling, please, across page 2 and on
to page 3. Thank you, stop. That all culminates in
a "Conclusion" by the Post Office. In this case, it
reads:
"In conclusion the evidence examined provides no
support for the Applicant's claim that the Horizon
System caused a shortfall in the branch. Given that no
systemic error has been identified in Horizon, the more
likely reason for the shortfall is user error or fraud
which could be due to the lack of poor controls in
place, eg sharing of usernames and passwords."
Was that the usual format: a narrative account of
30
et cetera, yes?
Yes.
If we scroll down, please, we'll see that fifth from the
bottom is M035_POL_Security Report_PT_012, and that's
described as a "Copy of the Security team report", yes?
That's correct.
So this was a document provided with this POIR?
This particular POIR, yes.
Yes. Can we look that document, please, the Security
Team Report provided with this POIR. It's POL00430943.
If we can just look at the top left-hand side of the
document, can we see that it's marked in that way?
Yes.
Is this what happened: that printed onto, or marked
onto, each of the documents that accompanied a POIR was
a copy of the document, but then it was branded with
the -- I'm going to call it an exhibit number?
Yes. Exactly how that all happened, I'm not clear.
But, certainly, the "M035" was the Second Sight
reference to Jo Hamilton's case.
So we can see from that marking that this is the
document that was being referred to, five lines from the
bottom on page 8 of the report, and so this is the
document that would have been sent by Post Office to
Second Sight, correct?
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With one qualification. I do recall -- I mean, this
became known as the "Brander report". The author was
a Post Office Investigator called Brander. I do recall
there were various versions of this report, which we
never got to the bottom of as to why there were
different versions --
I'm going to try to explore that with you in the next
ten minutes or so.
Okay.
If we just scroll down, we're quite familiar with these.
This is the original Security Department report prepared
in Ms Hamilton's case. If we go to page 9 and scroll
down, we'll see that it's dated 17 May 2006, by Graham
Brander, the Investigation Manager, yes?
Yes.
If we look at the top, the page, we can see again, it's
marked with that -- I'm going to call it an exhibit
number, yes —-
Yes.
-- and every page is marked in that way? So this is the
original Security Department, Security Team report, with
the purposes of the proposed prosecution of Ms Hamilton.
Can we look, please, at page 4, and the second
paragraph from the bottom. This is in a part of the
report that the Investigator, Mr Brander, is setting out
33
We know that you subsequently referred to the contents
of this report in your Case Review Report for
Ms Hamilton?
Yes.
Did you know that the purpose of these reports was to
seek legal advice from the Criminal Law Team?
It's a difficult question to answer. I mean, these were
reports prepared by an experienced Post Office
Investigator. In many cases, no further action was
taken; in other cases, prosecutions were considered.
So, in this particular case, I was not aware that this
report was addressed -- was prepared on the instructions
of a lawyer or intended to be passed on to a lawyer.
Did you feel inhibited in any way, in the circumstances
it was given to you and in the light of any markings on
it, in referring to the contents of it in your Case
Review Report?
No, I didn't.
Can we see what you did with this important information,
then, please. POL00063517. Is this a copy of your Case
Review Report in the case of M035, Josephine Hamilton?
Yes, it is.
We can see it's dated 24 March 2015. If we just scroll
through the first couple of pages, we can see there's
an introduction setting out the terms of reference.
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the investigations that he conducted and the results of
them. Can you see the second paragraph from the bottom,
the second part of it:
"Having analysed the Horizon printouts and
accounting documentation I was unable to find any
evidence of theft or that the cash figures had been
deliberately inflated.”
Now, you tell us had this was, in your statement,
this was an important statement from the Investigator,
agreed?
Correct.
Was it important to you because you knew that
Ms Hamilton was, in fact, charged with theft?
Yes. I found it quite an astonishing statement in the
context of what she was charged with.
This was something that I think you spotted at the time?
Yes.
Now, if we look at the top and the bottom of each page,
and go back to page 1, and look at the front page and
look at the foot of the front page, thank you, we can
see that document, the report, is not marked as “Legally
Privileged” or "Subject to legal professional privilege"
or otherwise referred as to being a privileged document,
correct?
That's correct.
34
Scroll on, please. The documents you have been provided
with -- just stop there.
At the top of the page, one of the documents that
you had been provided with was the Post Office
Investigation Report. That's what we've just looked at,
correct?
Yes.
If we can scroll forwards to page 6, please, and read
paragraph 4.10.
"The documents submitted by the Post Office include
a Post Office Investigator's report, dated 17 May 2006
That's the Brander report we've just read, you've
got the correct date.
Yes.
"... (see Post Office Document 012) ..."
That's the right number because that's the suffix of
the document we've just looked at:
hat includes the following statements:
‘Having analysed the Horizon printouts and
accounting documentation I was unable to find any
evidence of theft or that cash figures had been
deliberately inflated’."
If we skip over two paragraphs, thank you, you say:
"In our opinion, the fact that the Post Office's own
36
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Investigator had found no evidence of theft as well as
the endemic User ID and password sharing in the branch
... would have been relevant to the applicant's defence.
No more detailed investigation was carried out by Post
Office until it was preparing its [Post Office
Investigation Report]."
Then in 4.11:
“As described ... below, we have not been provided
with the complete legal files, which would enable us to
investigate this matter in more detail. However, on the
basis of the limited documents made available to us, we
consider it to be possible (though it is clear to us
that Post Office does not) that.
a) the Prosecution realised that there may have
been insufficient evidence to support a charge of Theft,
but proceeded with it nonetheless:
“b) the offer by the prosecution to remove the
charge of Theft may have been used to put pressure on
the applicant to plead guilty to the False Accounting
charges, even though the prosecution may have realised
that a charge of Theft was likely to fail unless further
evidence was ... discovered to support that charge;
"c) the threat of proceeding with the charge of
Theft may have been used to put pressure on the
applicant to agree to repay the losses and to avoid the
37
case.
Correct.
Let's read it in full. We should look at the second
page first. We'll see that it's signed by Rodric
Williams, although we know from other evidence that this
was drafted for Rodric Williams by Andrew Parsons. If
we go up, please:
"We refer to the above applicant [that's
Ms Hamilton] and, in particular, to your Case Review
Report dated 24 March [that's what we've just looked
at].
"At paragraph 4.10 of the [Case Review Report], you
quote from a ‘Post Office Investigators Report dated
17 May’ (the 'Security Report’). At paragraph 4.11 of
the [Case Review Report], you speculate about the impact
the Security Report may have had on the criminal
prosecution brought against the Applicant.
"The Security Report was not appended to the final
version of the [Post Office Investigation Report]
because it is protected from disclosure by legal
professional privilege. That privilege belongs to the
Post Office and does not extent to anyone beyond Post
Office and its professional advisers. Post Office
continues to assert privilege over the Security Report.
“As a consequence of your disclosure, on 6 May 2015
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custodial sentence normally associated with a conviction
for Theft;
"d) the purpose of proceeding with a charge of Theft
may have been intended primarily to assist in the
recovery of losses, rather than in the interests of
Justice; and
"e) part of the agreement to remove the Theft charge
included a demand that no mention would be made in court
of alleged problems with the Horizon computer system.”
Now, there's a wide range of conclusions reached
there but are they founded, in part, on the inclusion in
the Brander report of a recognition by him that there
was no evidence to support a charge of theft?
Yes, they are.
Was that very significant information for you,
therefore?
Yes, it struck me that it was exculpatory evidence that
had not been disclosed to Mrs Hamilton or her Legal
Team.
You were pointing it out to the Post Office in clear
terms in this, your Case Review Report?
Yes.
Can we see what happened next, please. POLO0025188. So
this is a letter of 2 June 2015, so it's about two
months after you prepared your report in Ms Hamilton's
38
we received a request from the applicant for a copy of
the Security Report which noted that the document quoted
in the final CRR at paragraph 4.10 was not present in
the pack of documents appended to the POIR."
Just stopping there, unpacking what that sentence
means, your Case Review Report gets disclosed to the
applicant, correct?
Yes.
Your Case Review Report included extracts from the
original Brander report?
Correct.
And it seems that, on 6 may, the Post Office received
a request for disclosure of that Security Report from
Ms Hamilton?
Yes.
"We have responded refusing the applicant's request on
the basis the document is privileged ..."
It seems like they attached a copy of the letter to
Josephine Hamilton:
"We nevertheless remain concerned about your
disclosure of the Security Report. Please therefore
explain to us in writing why:
"1. You considered its disclosure to be consistent
with the undertaking provided on 19 October 2012, a copy
of which is appended to this letter, confirming that
40
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certain documents provided by Post Office are
privileged, [and] the benefit of that privilege shall at
all times belong to Post Office, and that the documents
and their contents ‘will be held in complete confidence
and will not be closed to any other party or used for
any other purpose whatsoever without the prior written
consent of the Post Office’;
"2. [You need to explain I writing why] you
referred to it when it was not appended to the POIR;
"3. [You need to explain in writing why] you
referred to it in your final report only, and not in the
draft CRRs on which Post Office was able to provide
comment;
"4. You commented on it as you have when you are
not in possession of all material information and when
matters of criminal law and procedure are outside of
your scope of expertise."
They look forward to hearing from you in seven days
and they reserve their position in the meantime.
Can we see what your reply was, please, to this
letter. POLO0065542. You reply the next day, so the
letter was dated 2 June and you replied on 3 June and
you say that you're replying on behalf of both you and
Mr Warmington. It's to Rod Williams, copied to Patrick
Bourke, Jane MacLeod, to Mr Warmington, to Chris
a
obviously concerned that other misclassified documents
may have been improperly withheld from disclosure.
"Dealing with the specific questions ...
"1. The undertaking ... is not relevant as the
"Security Report’ was disclosed to the Working Group,
including Second Sight, in accordance with the terms of
reference of the Working Group;
"2. It formed part of number of documents disclosed
to the Working Group that were considered within the
[Post Office Investigation Report];
"3. Second Sight considered number of
representations and other matters after disclosure of
the draft CRR. This resulted in the CRR being updated
and finalised;
"4. We have requested access to the complete legal
files held by Post Office relating to this and other
cases. However, this access has not been provided,
which we regard as regrettable. [This] limitation [of]
scope was made clear in the final CRR."
You explain, just taking the facts to their final
conclusion at the moment, in your witness statement,
that the Post Office's solution to this was to create
a new investigation report, POIR, which deleted any
mention of the original Security Report, correct?
Yes.
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Holyoak, who was one of your investigators, is that
right --
Yes.
-- and to Mark Underwood?
He was Post Office, I think.
Yes:
"Thank you for your letter ...
"The main premise of your letter is not correct.
The document in question, (the ‘Security Report’),
was quite properly disclosed to Second Sight and the
Working Group via Huddle around March 2014. I attach
a copy of the document that was disclosed to us. I am
sure that the Huddle audit logs will provide further
information about this disclosure"?
Huddle was an e-disclosure platform?
Document sharing system that we were using, that was
managed by Post Office.
You continue:
"The document was not marked as being subject to
[LPP] and a careful reading of the document does not
find any mention of legal advice, the normal basis upon
which [LPP] is claimed.
"I would be grateful if you would explain in detail
why you now consider this document to be subject to
[LPP] and therefore protected from disclosure. I am
42
Let's look at POL00034782, page 7, please. If we can
look at that alongside POL00034551, at page 8. If we
scroll down on the left-hand side to the bottom, we can
see it there, document number 12, a copy of Security
Team Report. So this is in their original POIR. Then
on the right-hand side, please, if we scroll down,
you'll see it's gone.
Can I just clarify: it is gone, however, the partial
document reference has remained much the same. It's
still POL_012 but it's now described as a "Security
Interview", not the Security Team report.
No, in fact what they've done, Mr Henderson, is they've
just renumbered them. If you look on the left-hand side
at what was 13, 14, 15 and 16 --
It's gone up from 13 to 12.
-- it's gone up from 13 to 12.
Yes.
So the document, the Security Team report, that
contained the passage that said that the Investigator
found no evidence of theft or deliberately inflated
figures, has been removed?
Yes.
Is this a fair summary of what we've seen, then?
Firstly, the Post Office had set up a mediation scheme
saying that it wanted to get to the bottom of complaints
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and concerns of subpostmasters?
Yes.
The Post Office said that, in some cases, it wished to
get to the bottom of the complaints that they made, that
there had been miscarriages of justice?
Yes.
The Post Office had disclosed a document to you that
contained important information that went to the
propriety of charging Josephine Hamilton with theft?
Yes.
That document wasn't marked as privileged?
Correct.
You referred to it in your report?
Correct.
The Post Office took a legal professional privilege
point to seek to prevent the disclosure of information
that was harmful to its interests?
Yes.
Josephine Hamilton asked for the original document, the
Post Office took the privileged point against her too?
Correct.
You got a written telling off?
Yes.
The Post Office provided a subsequent version of its
report, in which the offending Security Team report was
45
seek the truth, irrespective of the consequences, and
that very much reflected Susan Crichton's view.
However, as things progressed, the attitude of Post
Office changed. They became much more adversarial.
I felt that they were protecting the brand, they didn't
want difficult information to see the light of day and
we were having to fight constantly for access to
documents that we felt were relevant to our work.
You said in your correspondence that you wanted access
to legal files but you never got them?
We were initially provided with access to the legal
files. I was based in the Legal Department. The
problem was, out of 700-odd prosecutions, they only held
about a dozen files. So there was a lot that we weren't
able to have access to. Fortunately, one of those files
was Jo Hamilton and it was that that enabled us to find
these documents.
When reading the correspondence, it doesn't look so much
as if it was by happenstance that you saw this
originally in the Post Office Legal files that you
examined from mid-2012 onwards; it was more that the
Post Office, in their view, accidentally disclosed
a copy of the Brander report, either on Huddle or as
an annex to their POIR?
I think what actually happened was that there was
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airbrushed out?
Correct.
You tell us in your witness statement that, when
Mr Williams asserted privilege over this document, you
found his assertion to be absurd?
Correct.
You found it to be immensely worrying and that, to you,
this began to look more like a cover-up than a genuine
concern about legal professional privilege?
Yes.
This sequence of events that we've just gone through in
Josephine Hamilton's case, looking at these documents,
was this one-off conduct by the Post Office?
I suspect not.
Was the type of correspondence that we've seen, looking
at these documents and your reply to the correspondence,
the type of correspondence you were engaged in with the
Post Office on a regular basis?
Yes.
Did that approach of the Post Office occur throughout
your initial investigation and the Mediation Scheme that
followed it?
I think, to be fair to Post Office, their attitude
changed over time. When we were first appointed,
I formed the view that there was a shared commitment to
46
a small number of files available to us in the Legal
Department. We were dealing with Jarnail Singh, Susan
Crichton. As far as I'm aware, external lawyers weren't
involved in the time -- at that time. Certainly
I didn't meet Andy Parsons until the Mediation Scheme
kicked off. And I think that's when Post Office started
getting very concerned about disclosing documents to us.
Can we turn, just before the break, to your witness
statement, please, at page 12, and paragraph 39 at the
foot of the page. Having dealt in paragraph 38 with
that extract from the Security Report you say in 39:
"I could also see that Jo Hamilton had been charged
with theft and false accounting which did not seem to be
supported by the internal [Post Office] Security
report."
Over the page:
"I raised this apparent inconsistency with Susan
Crichton and was told to speak to Jarnail Singh, which
\ did. Jarnail told me that everything that needed to
be disclosed had been disclosed and there was nothing to
worry about."
First of all, can you help us as to when these
conversations with Susan Crichton and then Jarnail Singh
happened?
It was when I was based in the Post Office Legal
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Department in Old Street. The exact date, I can't
recall, I'm afraid.
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So that would be in the early stages of the initial
investigation --
Yes.
-- from sort of June --
2012 --
-- 2012?
Yeah.
pPrporop
as part of the Mediation Scheme that we've just looked
at?
A. No, this was when we first had, or when I first had,
access to the files in the Legal Department.
Q. So you spotted it then as well?
A. Yes. I spotted it as an apparent inconsistency, which
concerned me.
Q. When Mr Singh said that everything that needed to be
disclosed had been disclosed, was he referring to the
criminal proceedings then, ie had been disclosed to the
defence in the criminal proceedings?
A. It was -- that was certainly the context. So I assume
that that's what he had in mind.
Q. Were you concerned about what he said?
A. I was very concerned. It seemed to be a breach of the
49
hear us?
SIR WYN WILLIAMS: Yes, thank you.
MR BEER: Mr Henderson, can we go back to September 2012 --
do you remember we jumped forwards -- by looking at
POL00181574. This is an email exchange internal to the
Post Office. Not something that you were copied into
but it relates to a meeting, at which I think you were
present, of 7 September 2012. Mr Baker says:
"Quick note from today's meeting with Second Sight."
At (1), he says:
"The number 1 issue is documentation, or lack of it.
They are beginning increasingly frustrated.”
Firstly, is that right: that by this comparatively
early stage, September 2012, you were becoming
increasingly frustrated with the lack of documentation
being provided by the Post Office?
A. Yes, we were.
Q. He, Mr Baker, says:
"Hopefully, things should start to get better as
Angela has kindly nominated someone in her team to help
us, and with Jarnail back next week we should be able to
get our hands on the prosecution files."
Then at (4):
"Second Sight have expressed an interest in viewing,
at a distance, how we approach a couple of live cases.
51
So this wasn't approximate to the production of your CRR
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Code of Conduct of Crown Prosecutors, which he had
a duty to comply with.
Did you have any concerns about Ms Crichton's reliance
‘on Jarnail Singh?
Yes. In the sense that she was a commercial lawyer, he
was a criminal lawyer, she was supervising a department
in charge of criminal prosecutions and that was not her
area of expertise, and she recognised that and relied
heavily on Jarnail Singh.
At the time, in mid-2012, was anything done about this?
Well, I raised it both with Susan and Jarnail. I don't
know what happened internally within Post Office.
This came back again, in the way that we've just seen,
in the Mediation Scheme, through the production of your
CRR?
Yeah.
MR BEER: Thank you.
Sir, it's 11.00 and therefore time for the morning
break. Can we break until 11.10, please?
SIR WYN WILLIAMS: Certainly.
MR BEER: Thank you very much.
(11.01 am)
(A short break)
(14.11 am)
MRBEER: Good morning, sir. Can you continue to see and
50
They are forming a view that we are poor at
investigations but before they put it into their report
would like to see how we now approach investigations as
they believe we may have improved."
Firstly, had you, by this time, early September
2012, formed the view that the Post Office was poor at
investigations?
We had, but in -- that view needs to be qualified
because it was solely on the basis of looking at some of
their case files: we hadn't spoken to any of their
Investigators; we hadn't had a discussion with them as
to how they approached investigations from a practical
point of view.
Did you express a desire to view at a distance some live
cases?
Yes.
The 10 or 12 -- I think those are the numbers you've
mentioned, case files that you saw at this early stage,
did they include the legal advice that the Post Office
was giving to its investigators?
Yes, as far as I can recall.
So they were the full prosecution files, in the sense
that they were the internal POL file that included
communication from Investigator to lawyer, and
communication from lawyer back to Investigator?
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The Post Office Horizon IT Inquiry
Yes, and just to put this in context, my access to those
files was approved by Susan Crichton, who is the Head of
Legal. I was sitting outside her office. She was
entirely happy that we were given access to everything.
The only limitation was that there was a relatively
small number of files held by Post Office in their Legal
Department in London at the time.
Did that openness or facility to look at legal files
continue throughout the initial investigation --
No, it didn't, it didn't, and I think it changed,
certainly after a few months when Post Office perhaps
realised that we were becoming quite critical of the way
that they conducted investigations and some of the
prosecution decisions that were being made.
So do I take from that that, in your mind, there was
a link between the view on the merits that you were
taking and the access to legal files that you were
given?
Yes.
At the very outset of your investigation, did the Post
Office tell you about the classes of documentation that
it held, for example, concerning the functioning of, or
deficiencies in, the Horizon system?
I don't recall that they explicitly referred to it in
that sense. The impression I formed at this stage,
53
emails, reports and the minutes of meetings regarding
bugs, of which the Post Office was already aware?
I can't recall the relevant or the relative timing of
that. I mean, we eventually got some limited disclosure
but that, I think, occurred much later on in the overall
process and certainly after I'd met with Gareth Jenkins
at Fujitsu.
Yes. So I'm talking about the initial stages: you're
brought in; you're sat next to Jarnail Singh, outside
Susan Crichton's office; you're looking into problems
with Horizon, the suggestion by subpostmasters that it
is faulty in its operation.
Yeah.
I'm looking to understand whether the Post Office said,
"We already know these things. Have a look at this
suite of documents which tell you about the bugs that we
already know about"?
No, there was nothing like that at that stage at all.
"We've known about the Falkirk bug since 2006, we've
known about the receipts and payments mismatch bug since
at least September/October 2010" --
No.
"this is what happened"?
None of that was disclosed at that stage?
At the outset of the investigation, did the Post Office
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which was sort of September/October 2012, was that Post
Office didn't really understand Horizon. They weren't
particularly interested in it. As far as they were
concerned, it was a black box that worked reasonably
well most of the time and they didn't take it any
further than that.
Did they tell you whether there was a central repository
of material held about issues concerning the functioning
of, or deficiencies in, Horizon?
Well, that was certainly a question that we asked and
I think the answer was, "No, we don't hold a single case
file sort of summarising those reports".
Did they inform you about the existence of release notes
that documented bug fixes or attempted bug fixes?
No.
Did they inform you of the existence of major incident
reports?
We certainly didn't see any major incident reports.
I think -- and I don't recall any discussions about
them.
Did they inform you about the existence of Service
Management documents?
No.
At the outset of the investigation, did the Post Office
provide you with documentation including, for example,
54
provide you with any expert reports regarding Horizon,
that the Post Office itself had commissioned in past
court cases?
Not that I can recall.
For example, the Jason Coyne report prepared in the case
involving Julie Wolstenholme in 2004?
No.
The BDO report in the Lee Castleton case in 2006?
No.
Did the Post Office provide you with witness statements
in past Post Office prosecution cases, which set out the
categories of documents that would be relevant to your
investigation, for example, the existence of a species
of documents known as PinlCLs or PEAKs, and a species of
documents called KELs, Known Error Logs?
No, they weren't disclosed at that stage or mentioned.
Did the Post Office tell you about previous acquittals
of subpostmasters, each of whom had raised, as part of
their defence, the faulty operation of the Horizon
system?
No, they did not.
At the outset of the investigation, did the Post Office
provide you with operational change proposal records
which set out the existence of a facility for remote
access?
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No, they did not.
What did they give you?
The position of Post Office -- and this was the senior
people that we were dealing with, principally Alwen
Lyons, Susan Crichton, Angela van den Bogerd -- was that
Horizon was working perfectly and there were no known
problems. That was consistently the Post Office
position at that stage.
So you were told, "Here are some files", and you were
given access to some prosecution files?
Yes.
Were you told or given the names of individuals that had
been acquitted: Nichola Arch, Suzanne Palmer, Maureen
McKelvey?
Not at that stage, no.
In your witness statement -- perhaps we'd better turn it
up. It's paragraph 53, which is on page 16.
Paragraph 53, you say:
"Within days of being provided with CD1 ..."
Do you just want to remind us what CD1 was?
Right, I need to step back slightly. September/October,
I was based in the Legal Department. We'd realised that
we needed to preserve and control the legal files that
were being made available to us, relatively small
number, and I think my suggestion was to make them more
57
"We've done everything that we need to do, there's
nothing to worry about".
So what happened to the concern that you were raising:
that you, Second Sight, may be looking at a significant
number of miscarriages of justice?
To a certain extent, we parked it at that point, because
we were still pressing for access to further files. We
knew that there were a much larger number of
prosecutions. What we didn't know was whether we'd get
access to other files, other than the ones held or
immediately made available to us.
Did you consider at this stage sharing your views with
the Crown Office and Procurator Fiscal Service in
Scotland?
No, we didn't consider that. I don't recall looking at
any Scottish cases at that stage.
Did you know that they were continuing with Scottish
Post Office prosecutions at this time?
No, I didn't.
I just want to test, if I may, this point that, in late
October 2012, you realised that you may be looking at
a significant number of miscarriages of justice, by
again looking forwards at POL00144687. Can we start on
page 2, please?
This, of course, is much later. This is May 2013,
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useful to us -- because these were, obviously, hard-copy
files not electronic files, in the main -- we asked that
they all be sent off to a scanning bureau and converted
into searchable pdfs, so that they could be used more
effectively, and that happened in October 2012.
By that stage, I'd conducted a manual review of
about a dozen files and realised that there were
significant, or potentially significant, numbers of
non-disclosure of information by Post Office that could
give rise to miscarriages of justice.
So you say:
"... we realised that we may be looking at
a significant number of miscarriages of justice. There
was a lack of effective investigation, multiple
disclosure failures and conduct by prosecutors that
needed to be considered by experts in criminal law and
prosecutions."
Yes.
At this stage, late October 2012, did you share any of
those initial views with the Post Office?
Yes.
With whom did you share them?
Certainly Susan Crichton and Jarnail Singh, and Susan
felt that it was outside her area of expertise. She was
relying on advice from Jarnail. Jarnail's position was,
58
I think.
Exactly. If we look at page 2 and scroll down. There's
an email from Mr Baker to Mr Warmington copied to you
and Alwen Lyons, and says:
"Ron
"Just to ensure we are on the same page, Paula would
like to say we have agreed the following with Second
Sight, can you confirm you agree."
Then:
"1. The investigation reports on 2-3 MPs cases by
summer Recess ..."
Then:
"2. By using the 2-3 cases you will answer the
question: have systemic defects in the Horizon system
resulted in the wrongful conviction or suspension of
subpostmasters?"
Then:
"4. From the investigation work done to date, if
question 2 was posed to you today, you would answer
‘no’."
If you'd already raised your concerns with the Post
Office about possible miscarriages of justice, can you
help as to why the Post Office were asking you to
confirm that your investigation work to date had not
revealed any wrongful convictions or suspensions?
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Well, I think if you look at point 2, it needs to be
broken down. There's two separate questions there. One
relates to were there systemic defects and, at that
stage, we weren't aware of any. But we were aware of
evidence that raised concerns about miscarriages of
justice, therefore the wrongful conviction of
subpostmasters.
Can we just look at what Mr Warmington replied, then, by
going back to page 1. He replies the next day, 22 May,
and says to Mr Baker:
"I'm surprised at the questions you have raised as
these include matters that are outside our scope of
work.”
Then skip over 1, and then answer to question 2, he
sets out the question that Mr Baker posed and replies:
"Our role is to establish the facts relating to
specific MP or JFSA nominated cases. We are not
qualified to answer a legal question about what may or
may not be an unsafe conviction or suspension."
Then (4), he says:
"Please see my response to question 2 abov
Again, if you had already raised your concerns with
Post Office about possible miscarriages of justice
wouldn't this have been the opportunity to include in
a reply "But as you already know, we have concerns about
61
You could, nonetheless, still make the point by saying,
"We are inexpert in this field but we've spotted things
that require to be investigated by an expert or assessed
by an expert” -
Yes.
-- or would that be outside your terms of reference --
No, I --
-- as you understood it?
I think we perhaps should have done more to highlight
the apparent sort of deficiencies in the prosecution
process that we'd identified. But we were equally
conscious that we were getting pushed back by Post
Office not to stray outside our terms of reference and
not to stray into areas of criminal law and procedure.
Was that a constant refrain from the Post Office?
It was certainly an attitude that we were very -- we
were well aware of and knew that, if we strayed into
that area, we would be challenged, I think quite
rightly.
Thank you. Can I turn to the issue of remote access,
please, and start by looking at a document, POL00029846.
To start with, can you help us what this is?
This looks as if it was one of the reports that Second
Sight produced.
Can we look, please, at paragraph 14.10 on page 2. You
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miscarriages of justice, because of ineffective
investigations disclosure failings, or prosecutorial
misconduct that we've suggested ought to be looked at by
an expert in criminal law?"
Yes, and I think that is the correct way to do it.
Second Sight was not an expert in criminal procedure
prosecutions. We, I think, quite rightly could be
regard as an expert in relevant evidence and it was the
evidential element that we had sort of concerns about,
and I think we certainly felt, at this stage, that those
matters needed to be considered by experts in criminal
procedure.
What I'm testing with you, Mr Henderson, is if, by
October 2012, you'd formed the view that there may be
miscarriages of justice because of poor investigations,
disclosure failings and other prosecutorial misconduct,
why we don't see it here in this email exchange or
indeed in your report of 8 July 2013.
I think we were concerned we didn't want to step outside
what Post Office regard as our terms of reference and
not to stray into areas where we didn't have the
relevant expertise, and that included these views on
criminal prosecutions. We were concerned about
non-disclosure of evidence that appeared to be relevant,
and that was our -- probably our main focus.
62
refer to a document called "Receipts/Payments Mismatch
issue notes", which appears to be a minute of a joint
Post Office meeting probably held in August 2010:
"The document refers to the impact of the bug as
being ..."
Now, we're very familiar with that document. If we
go over the page, Solutions One, Two and Three are set
out.
Now, in this document that we're looking at, at the
moment, which is essentially a briefing note --
I think produced by Fujitsu; is that right?
Hold on, the document we're looking at is produced by
Second Sight. You're referring to a meeting note. Can
you recall how it was that you came to see the meeting
notes referring to Solutions One, Two and Three?
I think it was a document that was disclosed to Second
Sight by Simon Baker, who was the project manager within
Post Office, who was our main liaison, particularly
between us and Fujitsu.
Can you recall when you came to see these meeting notes.
We, at the moment, have not been able to see documentary
evidence of you being provided with them and, therefore,
able to date the provision of them to you, and where
they came from, albeit it is plain from this document
that you had got them?
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I think it was very shortly before one of our reports.
Exactly which report, I'm not sure. This, I think, was
the Part 2 report.
Yes.
But the exact date that it was first disclosed to us,
I can't recall.
But you remember it being handed to you or sent to you
by Simon Baker; is that right?
Yes.
Thank you. Okay, that can come down.
Can we go back to your witness statement, then,
please, and look at paragraph 43, which is at the foot
of page 13. Page 13, paragraph 43, you say:
"In September 2012 I met with Gareth Jenkins, the
lead engineer for Post Office Horizon, at the Head
Office in Bracknell. He told me that approximately 10
members of staff from Post Office were permanently based
in Bracknell, dealing with various issues including
bugs, errors and defects."
Then 44:
"Gareth Jenkins told me that Fujitsu routinely used
remote access to branch terminals for various purposes.
This was often without the knowledge or specific consent
of individual subpostmasters. He also told me that
members of his team could connect remotely to branch
65
manager, something that he had previously been unaware."
You tell us in 48 that, about this point, you
decided that:
"... the best way to resolve the issue was to
request the full email archives for the [Post Office]
employees at Bracknell, as this would shed light on what
they were actually doing."
By this time, had Michael Rudkin made an allegation
that, during a visit to the basement of the Fujitsu
office in Bracknell in August 2008, an individual had
demonstrated their ability to alter branch accounts
remotely?
I think so and that was one of the reasons why we wanted
to visit Bracknell and see what was actually happening
‘on the ground.
Rather than requesting full email archives to
investigate the issue, could you not have asked
Mr Jenkins to provide written confirmation supporting
what he had told you rather straightforwardly in the
meeting?
Yes, we could have done and, with hindsight, we probably
should have done. Bear in mind that the meeting with
Gareth Jenkins I'd always seen as a preliminary meeting
to have, you know, some contact, to hear directly from
the Horizon lead engineer, the architect of the system,
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terminals and generate keystrokes that were
indistinguishable from a subpostmaster accessing the
terminal directly. They did this for various purposes,
including collecting log files directly from branch
terminals.
“In my opinion, this facility (if confirmed) had
major implications for the safety of criminal
convictions, as it meant that the subpostmaster was no
longer in sole charge of data entries being input on his
terminal."
At 46, you say you:
"... subsequently shared the information with Alwyn
Lyons ... and Lesley Sewell ... and was told quite
firmly that [you] were mistaken and that [Post Office]
had received assurances about this in various audit
reports. This point was made very firmly to me [you
continue], and I recall telling Ron Warmington shortly
afterwards that I felt that if I made an issue of it
there was a significant risk of Second Sight being
sacked."
Then 47:
"I also discussed the issue of [Post Office]
employees working at Bracknell with Simon Baker. He
told me that he had researched the issue and was
surprised to find that he in fact was their line
66
what was available, what wasn't available, and so on,
and, even though I only had one meeting with Gareth
Jenkins, we did have quite extensive follow-up
correspondence where he sent me various internal reports
and documents.
Can I just attempt to nail down with precision exactly
what was said, by looking at a witness statement that
you provided in the Horizon Issues trial. That's
POL00091426. This is your witness statement in the
Horizon Issues trial. You'll see it's dated
28 September 2018.
Yes.
Can we turn to page 3, please, and look at
paragraph 2.2. You say:
"On 13 September 2012, I met with senior
representatives of Fujitsu at their Bracknell office.
One of the people who attended was Gareth Jenkins, who
I believe was the Fujitsu lead engineer on the [Post
Office] contract. He subsequently provided me with
a number of technical reports describing the Horizon
system and architecture and, as would be expected, he
was obviously knowledgeable about its operation. At the
meeting on 13 September 2012, one of the matters
discussed in the meeting was remote access to terminals
locate in branches. Gareth Jenkins confirmed to me that
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this capability existed and was occasionally used to
troubleshoot problems in the branch."
Just stopping there, I'm not going to look at it at
the same time but in your current witness statement you
say, paragraph 44:
"Gareth Jenkins told me that Fujitsu routinely used
remote access to branch terminals for various purposes."
That seems to be slightly different, a routine use
of it for various purposes, whereas, in this earlier
statement, you said that he told you that it was
‘occasionally used to troubleshoot problems. Which do
you think is more likely to be accurate: your earlier
statement or the one you've made now?
I think you need to drill into the detail because, on
reflection, I realised that Gareth Jenkins was talking
about a number of different things. At one level, he
was talking about direct access to physical sort of
terminals, using things like remote desktop protocol,
where he was troubleshooting, it might be hardware
failures, connecting to a terminal in a subpostmaster's
branch. But I'm also now aware that remote access also
extended to include back-end databases, and so on.
At the time that both these statements were made,
I was probably unaware of that level of detail.
You say in your Inquiry statement that Mr Jenkins told
69
Do you think there's a possibility that that was.
something -- ie the ability to generate keystrokes that
are indistinguishable from those of the subpostmaster --
which you have later learned?
No. Again, I do recall that the exact technical method
of accessing a branch terminal was described to me in
September 2012.
That can come down. Thank you. Irrespective of the
frequency of remote access and the nature and purpose of
the remote access, would you agree that Mr Jenkins was
being quite open with you in your 13 September 2012
meeting that Fujitsu had the capability to use, and in
fact had used, remote access in a way that affected data
in branch accounts?
Yes, I felt he was being very open. If there was any
sort of deficiency in our discussions, it was my failure
to ask further questions. I mean, for example, at that
stage, I was unaware that he'd given expert witness
statements in relation to his work.
Did it appear to you that Mr Jenkins understood the
implications of the facility remotely to access branch
accounts for criminal investigations and criminal
proceedings?
I think I probably felt at the stage, at that time, that
he did not appreciate that. As far as I was aware, he'd
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you that the capability was often used without the
knowledge of subpostmasters. In this account of the
meeting, you don't say one way or the other whether he
said that or not.
Well, we were talking about the technical sort of
capability. What he did tell me was that, in order for
this remote access to take place: (a) it was often done
out of hours, (b) he would often ask the subpostmaster
to leave the terminal switched on overnight to
facilitate that access. I apologise for not going into
that level of detail but I do recall that's what he told
me.
Thank you. Then, thirdly, in your Inquiry witness
statement, you say that he told you that he and his team
could remotely access branch terminals and generate
keystrokes that were indistinguishable from those
keystrokes of subpostmasters. That's not something
mentioned in this account of the meeting.
No, it's not. But I do recall -- and, again, I was
trying to strike a balance between getting into some of
the sort of the technical detail that perhaps would not
be understood generally, such as the exact mechanics of
how he did it, using, as I mentioned, remote desktop
protocol and the wider sort of capability of what he was
describing.
70
never been trained in expert witness evidence, and
evidence generally: he was a lead technical architect,
that was his area of expertise.
Did, in this meeting, Mr Jenkins disclose the existence
of any bugs, errors or defects to you?
Well, firstly, I don't think that was a term that he
used. He was probably -- you know, the preferred term
tended to be “anomaly” or "error". We certainly sort of
discussed that but we didn't explore that in any great
deal. He did offer to provide me with various reports
subsequently, which he did do.
You say that you raised this with Alwen Lyons and Lesley
Sewell. Did you receive any assurances or indications
from either of them that they would pursue the matter
with Gareth Jenkins?
No, in fact, almost the contrary. I was told in very
clear terms that I was mistaken, I must have
misunderstood what Gareth Jenkins had told me and that
they had third-party independent reports confirming the
reliable of Horizon, and that I was quite wrong in what
I'd reported to them.
So it wasn't the case that, in your conversations with
each of them, you formed the impression that the Post
Office knew already the substance of what Gareth Jenkins
was telling you directly; it was, instead, they denied
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its truth and accuracy?
Correct.
Did they mention from whom any reports had been received
or investigations conducted, the third parties?
I recall certainly the suggestion was third-party audit
reports, maybe Ernst & Young, something like that. But
again, I can't recall at this stage.
Were you at all insistent with them that they should
speak to somebody who was one of the principal
architects of the Horizon system and viewed by the Post
Office as the person from Fujitsu who could speak most
knowledgeably about the operation of Horizon, that they
needed to pursue this matter with him, given there was
a plain conflict in what you were being told?
I certainly agree that there was a conflict of evidence.
felt at this stage that there was such a gap between
what I had reported and what I was being told by Alwen
Lyons, Lesley Sewell, in particular, was that it was not
appropriate to pursue it further at that stage. It was
then something that I took back and discussed with Ron
Warmington.
You, I think, formed the view that this did have some
implications for the propriety or reliability of
prosecutions or the evidence relied upon in
prosecutions?
73
positions.
Can you explain in any more detail what Alwen Lyons or
Lesley Sewell said to you?
I recall very clearly what they said to me: I must be
mistaken. I told them about my conversation and they
told me that they had been assured by various
independent audit reports that what I had described
could not happen.
Why did you think that, if you made an issue of the
issue, there was a significant risk of Second Sight
being sacked?
The ferocity at which the strength of feeling was put to
me led me to think that. It was more a response at
an emotional level, perhaps, but it was made very clear
to me that it was not something that Post Office would
welcome being pursued.
Did you, in fact, not pursue it further?
I certainly discussed it in detail with Ron Warmington.
I think our position was we're dealing with a potential
conflict of evidence, rather than make a major fuss at
this stage, let's sort of tuck it away, see what further
corroboration we can get as our work continued.
I think you had been a party to -- or you knew about
a telephone conference and, in fact, joined it earlier
than this meeting with Gareth Jenkins -- involving
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Yes.
Were you concerned about a failure by the Post Office to
disclose in prosecutions what you had been told by
Mr Jenkins?
I think I was concerned but I was -- I had not been told
by Gareth Jenkins or anyone else at that stage that
Gareth Jenkins had provided expert witness statements in
terms of the matters that he dealt with.
Irrespective of his personal position and whether he was
under an obligation to disclose it when he gave
evidence, whether written or oral, more generally, you
had got somebody with significant knowledge of the
operation of Horizon telling you this information, which
you've summarised for us. Whether Post Office needed to
be disclosing that in current prosecutions or ought to
have disclosed it in past prosecutions, was that not
a concern?
I think it probably was but it was quite difficult to
deal with because, on the one hand, I was very clear in
terms of what the lead engineer from Fujitsu had told
me. But I was also very clear as to the position being
taken by Post Office, which was that Horizon was -- did
not have problems and there were -- you know, and these
matters did not need to be disclosed. It was a conflict
of evidence and I was struggling to reconcile the two
74
Gareth Jenkins; is that right, back in July?
I can't recall the relevant positioning but I'm happy to
accept that.
Okay, let's look at a document to help you out,
FUJ00232048. I don't think this is a note you would
have seen at the time but you have subsequently seen it.
It's a telephone conference note of 27 July 2012 and
you'll see that you're listed as present on the call,
along with Simon Baker and Jane Owens from the Post
Office, and Penny Thomas and Gareth Jenkins from
Fujitsu. Would this have been the first contact that
you had with Mr Jenkins?
Simon Baker acted as a liaison sort of point. So
I think the first time I had any contact with Gareth
Jenkins was when I visited Fujitsu, I think, in
September 2012. So, um ... yeah.
Can you see in the second paragraph:
"Gareth explained the audit of the activities of the
counter system which is retained for 7 years. We can
provide transaction records for 31 days per outlet which
equals 1 ARQ."
Then, if we scroll on, and then three paragraphs
from the bottom, now four paragraphs from the bottom:
"Gareth suggested a workshop to discuss the system
architecture. [Post Office]/AF ..."
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Not sure what "AF" means.
"AF" was Advanced Forensics, which was the trading name
of my business at the time.
Thank you. So:
"[Post Office/Second Sight] thought that this was
a good idea."
Is that what led to the meeting of 13 September
2012, that we've just referred to?
Yes, it is.
That was essentially a workshop that you've described in
paragraph 43 onwards of your witness statement?
Yeah, we had various sort of discussions about the best
way to move this forward. I recall also there was
a suggestion that we used the model office, which was
a facility within Old Street that was a demonstration
branch, Post Office branch terminal, that we were
offered as a facility. But we felt that, in the first
instance, a face-to-face meeting with Fujitsu was the
best way forward.
Now, the next paragraph:
“Raw data is not part of this service although we
may be able to provide.”
In context, is that Fujitsu speaking there?
Yes.
"Raw data is converted to XML."
77
I did and he was very helpful throughout. I've got no
criticism of him in terms of answering my questions and
providing support.
I think you went a little further, we're going to see,
in a call that you had with Simon Baker. If we can look
at that, please. SSLO000103. This is a transcript of
a call that I think you recorded; is that right?
No, I think it was recorded by Ron Warmington.
I see. It's undated. I've no doubt if we went through
all 17 pages you could approximate its date --
The context puts it, I would have thought, September
2012, or thereabouts.
Can we just turn to page 6, please, halfway down.
Mr Baker says:
"Okay, so I'm going to take your advice. I'm not
going to pick up SRO5."
That's Spot Review number 5, that concerns Michael
Rudkin's allegations; is that right?
Yes.
"I am going to, sort of, continue to dig around, I think
... just for my own benefit, and also I think I want to
keep Alwyn and Susan informed of what I've come up with,
because for them... you know, of what's going on.
Because they are not aware of any of this by the way.
"Okay.
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There's a commercial discussion to be had there too,
it is said.
Do you understand this now, or remembering back to
the day, that this was a proposal for a workshop and
that Second Sight should receive raw data in XML format?
Yes, I recall this. There were basically two main data
formats that were potentially sort of relevant: ARQ
data, Audit Request Query data; and XML data, which
stands for Extensible Markup Language, which was
a technical term for another type of computer data.
In this meeting was Mr Jenkins taking, on the face of
it, a constructive approach to the engagement with
Second Sight?
Yes, but also a commercial approach, in as much that
there'd be a cost of producing this data. I recall at
some point -- now whether it was at this stage or
subsequently, I can't remember -- that I was told that
Post Office had an entitlement to, I think from memory,
12 ARQ reports per month but, under the Service Level
Agreement between Fujitsu and Post Office, they were not
entitled to XML data and that there would be a charge
for any XML reports, and Post Office were very reluctant
to incur further expenditure.
Did you take a view, in your dealings with Mr Jenkins,
as to the extent to which he wished to help?
78
"Because I've told them that I've just found out
from Fujitsu that there is a mechanism, and their faces
dropped.
“lan Henderson: And by the way, I mean, one of the
key emails, you know, has Gareth Jenkins’ name all over
it. So it was absolutely clear that this was a widely
understood capability within the system.
"Simon Baker: Well, Gareth did -- Gareth is the one
that told me yesterday, and he didn't make any effort to
hide it."
You:
"No, I'm not surprised. Gareth Jenkins has always
struck me as, you know, straight as a die.”
Mr Warmington:
"Yeah."
You:
"And, you know, I'm very happy to sort of deal with
him. So what you've identified is pretty much what we
found going through the emails, or certainly one aspect
of them."
Can you help us. What was it in your dealings with
Mr Jenkins that struck you and allowed you to say that
he was straight?
He was not being evasive; he was happy to help; he was
answering my questions; he provided promptly with
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follow-up material that I requested; I mean, there was
no hesitation in his willingness to answer our questions
and to provide assistance.
Q. So he was willing to discuss remote access when the Post
Office was not?
A. Yes.
Q. Can we look at a second example of you expressing a view
on Mr Jenkins. SSLO000108. You are part of a call here
with Paula Vennells, Mark Davies, Alwen Lyons, Susan
Crichton, James Arbuthnot and Mr Warmington. This one
is dated. This is 22 July 2013. Can we just go forward
to page 11, please. Mr Warmington says:
“lan, one other point supporting what you just said,
we've had incredibly high quality material put together
by Gareth Jenkins of Fujitsu, who obviously knows the
system like the back of his hand, and do I get the sense
that he's coming up to retirement? That could be quite
a problem for us, if he's about to leave. Did you get
this?
"Susan: to be honest, Ron --
“Ron Warmington: I got that from lan. lan, did
I imagine that or did you mention that to me at some
point.
"Susan: let's take that offline, I think."
You:
81
a sensation that he felt that Post Office maybe didn't
take them particularly seriously, or didn't understand
them, or weren't that interested in them. Looking back
on it, that's a feeling that I've got. I'd be hard
pressed to sort of pin it down any more than that.
MR BEER: Thank you, Mr Henderson.
Sir, it's 12.05. Can we take our second break until
12.15? That's the end of a topic.
SIR WYN WILLIAMS: Yes, of course.
MR BEER: Thank you, sir.
(12.05 pm)
(A short break)
(12.15 pm)
MR BEER: Good afternoon, sir, can you see and hear us?
SIR WYN WILLIAMS: Yes, thank you.
MR BEER: Good afternoon, Mr Henderson.
In your witness statement at paragraph 30 -- no need
to turn it up -- you refer to the agreed goal between
the Post Office and Second Sight, at the outset of your
investigations, to be "to seek the truth irrespective of
the consequences". Was that the shared goal as.
articulated to you by the Post Office at the beginning
of the enterprise?
A. I think that was articulated more by James Arbuthnot and
MPs, which Post Office agreed to at the outset. So that
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"Yeah.
"Mr Warmington: ... He is a particularly high
quality individual and has done -- what he writes is
really good. So, you know, if that were to be the case
Fujitsu would need to field somebody nearly as good."
Ms Vennells intervenes. Then, at the foot of the
page, you say:
"He's superb and he's sufficiently sort of mature to
actually almost be independent, you know, even though he
is a Fujitsu", and I think you meant employee.
Can you explain us to what in your contact with
Mr Jenkins gave rise to this observation about
independence and maturity?
I saw him as a technical expert and that he approached
things from a technology perspective almost exclusively.
He didn't strike me as a company person or feeling that
he had to stick to a particular party line, in terms of
supporting Fujitsu. He was dealing with things at
a technical level, as a technical expert, and I found
that rather refreshing.
Was he taking the defensive position that the Post
Office was, which you describe in your witness
statement?
No, I think he was taking the view that he was providing
various reports to Post Office. I probably had
82
was the phrase that I associate with the very early
stages of our work, or our contact with Post Office.
You tell us in your witness statement -- no need to turn
it up, it's paragraph 45 and we've discussed it
already -- of instances where you sought to query the
safety of criminal convictions but your queries were
disregarded. How is that consistent with a shared
desire to seek the truth, irrespective of consequences?
I think that comes back to a strongly held view by Post
Office, which we agreed with: we were not experts in
criminal law, we were perhaps experts in evidence, and
I think the inconsistency is explained by the two stages
in that process. We might find evidence that we think
needs to be reviewed by experts in criminal law but that
would not be done by ourselves.
You tell us -- we should turn it up, please -- at
paragraph 88 of your witness statement, which is on
page 28, which is at the foot of the page, that:
"[You] remember that at the conclusion of one of the
[Working Group] meetings, the acting [Post Office] Head
of Legal (Chris Aujard) warned me to be careful about
what I said. He told me that if I said anything that,
harmed [Post Office], [Post Office] would not hesitate
to take legal action against me under the terms of my
Non-Disclosure Agreement and that I would not be able to
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afford the legal fees. I took this as a thinly veiled
threat to bankrupt me if I continued causing trouble.”
Can you remember the circumstances in which that
veiled threat was made?
Not in any great detail, other than it was in the
context of the mediation's Working Group. I mean, the
Inquiry has heard evidence from Chris Aujard. He came
across as an ambitious and, frankly, somewhat aggressive
lawyer and that was reflected in the way that he dealt
with Second Sight, to a certain extent. He was
obviously concerned about some of the things that I was
saying or raising in Working Group meetings and, yeah,
I mean, I remember this conversation. I thought it was
inappropriate and, to a certain degree somewhat
surprising but --
What had happened to the shared desire to seek the truth
irrespective of the consequences?
I think we'd moved on from that!
I'd formed the view that, quite early on in the
process, Post Office was getting advice from external
lawyers about the financial consequences of what we were
finding. The fact that they might be looking at very
material amounts of compensation. I remember doing
a back of a cigarette packet calculation and I felt
that, if all of the claims being raised by
85
12 months of starting our work and as we started
uncovering more and more evidence and we were identified
as a potential threat to the Post Office business model.
Can we turn to page 21 of your witness statement,
please, the paragraph at the top. You say:
"Whilst this [that's a Post Office document dated
April 2013, you're talking about there] accurately
describes what MPs wanted, Paula Vennells was
increasingly attempting to steer us away from
considering the safety of convictions."
Firstly, what did Paula Vennells do to attempt to
steer you away from considering the safety of
convictions?
I can't remember precisely but I do recall that the
Mediation Working Group, she didn't want criminal --
cases involving criminal convictions even to go to the
Mediation Working Group. The terms of the Mediation
Working Group specifically allowed that to happen --
I don't know how hard Post Office fought behind the
scenes to prevent that -- and we followed the terms of
reference of the Mediation Working Group but we were
aware, from Paula's public comments and feedback from
other Post Office employees, that they would not support
mediation involving criminal convictions, or were very
reluctant to do that.
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subpostmasters in -- through the Mediation Working Group
materialised, we were looking at, at least, £300 million
in compensation. That was a huge underestimate but
those were the sort of numbers I had in mind at the
stage.
I think that worried Post Office. They saw it as
an existential threat to their business model. They
were looking at further funding from the Government,
they were very concerned about the PR aspects of their
business model. PR was driving a lot of the decisions
in Post Office at this stage.
How did you know that?
Through contact with Mark Davies, who was the head of
PR. It was very clear that Post Office senior
management were very concerned about the public
perception, the brand image. I mean, Paula Vennells in
meetings was very open about it. She was determined to
promote the brand of Post Office.
You tell us in your witness statement -- no need to turn
it up -- that protecting the brand was the priority, not
supporting the subpostmasters; you felt that Post Office
had lost its way.
Yes, very much so.
When did this become evident to you?
Not to start with but probably within the first
86
Can we turn to page 53 of your witness statement,
please. At paragraph 142, you pick up this theme. You
say:
"[She] frequently and consistently attempted to
steer Second Sight away from investigating potential
miscarriages of justice. Another example was Post
Office's attitude towards criminal convictions and the
Mediation Scheme.
"The Scheme documentation made it quite clear that
an applicant with a criminal conviction was potentially
eligible for the Scheme. [Post Office] seemed to
disagree with this view and often challenged these
applications.
"When I first met Paula Vennells, she told me that
[the Post Office] was the nation's most trusted brand
with a history of over 400 years. As our work
continued, I increasingly formed the view that because
of this history, [Post Office] somehow felt it was above
the law and didn't need to comply with eg the Criminal
Procedure and Investigations Act 1996, which set out the
disclosure requirements for prosecutors (including those
conducting private prosecutions) as was the case with
[the Post Office].”
In what context did Ms Vennells frequently and
consistently attempt to steer Second Sight away from
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investigating potential miscarriages of justice?
The first thing I'd say is we had relatively little
direct contact with Paula. I mean, she certainly took
part in some of the telephone calls, conference calls.
The words that I'd quoted were made in evidence to the
Select Committee but, through Angela van den Bogerd, and
so on, and through their actions, in terms of making
documents available, there was clearly a problem in Post
Office's mind with the mediation of criminal
convictions.
In your witness statement, at paragraphs 159 onwards, if
we can turn those up please, from page 58 -- so
paragraph 159 -- you say:
"I have been asked [by the Inquiry] to reflect on
what I would have done differently ..."
You say:
"... a significant weakness in our relationship with
[the Post Office] (and the Scheme) was the lack of
independent oversight. Despite being owned by the
Government, [the Post Office] is treated as
an autonomous ‘arm's length body’. There was little or
no external scrutiny of the Board or its decision
making. The Government appointed the Chairman of [Post
Office] and also two Non-Executive Directors. It
probably would have been better if Second Sight had had
89
address this omission."
Firstly, can you explain what you would have wished
to have blown the whistle on?
I think I was concerned, as our work proceeded, that we
were coming across evidence of misconduct by
prosecutors. We raised those issues internally within
Post Office but we couldn't take it any further forward.
As you've referred to, we were threatened -- and I mean
that quite sort of sincerely -- with sanctions if we
breached confidentiality, if we breached non-disclosure.
I feel that in some circumstances there should be
an alternative option available to companies like Second
Sight, if we followed everything that was available to
us and still felt that matters needed to reach a wider
audience.
You make a comment about accountability in 161, which
I'm going to skip over, and in 162 and 163 you say:
"[You'd] like to say something about to whom we owed
a duty. [You] tried to go to where the evidence took
[you], but increasingly we were facing evidence of
questionable conduct by [Post Office], some of which, in
my opinion, was probably criminal.
"In the course of our work, I increasingly felt that
our overriding duty was, in a phrase attributed to Alan
Bates, to help 'the skint little people’ who didn't have
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a direct reporting line to the [Post Office] Chairman
and the [Post Office] Non-Executive Directors."
I take it that that's something that didn't occur to
you or Second Sight at the time?
Correct.
Were you ever asked, when conducting either the initial
investigation or your work in the production of reports
and contributions towards the Mediation Scheme, to
attend upon the Post Office Board?
No, we weren't and I think that was a mistake, a mistake
both by Post Office and also a mistake by Second Sight.
It's probably something we should have insisted on. We
did have a meeting with the Chairman of Post Office
towards the end of our -- or, in fact, after we'd been
sacked but that was the only time that we met anybody
from the Board.
You say in 160:
"There was one other matter that I wish to bring to
the attention of the Inquiry. That is the provision of
a whistleblowing facility. If I had been an employee of
[the Post Office], various protections would have been
available to me. However, as a contractor operating
under a draconian [NDA], no equivalent protections were
available to me. I regard this as regrettable, and I do
hope that the Government considers legislation to
90
a voice and had been so badly treated by [Post Office]."
Can I look, please, at an email, POLO0102280. This
an email towards the end of your engagement with the
Post Office. It's from Mr Warmington to, ostensibly,
you but also to Lord Arbuthnot's Chief of Staff, Janet
Walker. You say, second sentence:
"fear not, we'll not let the [subpostmasters],
JFSA, James and his colleagues (and you) down. But the
situation has become ludicrously untenable. It's clear
that the Legal Team in Post Office no longer accepts (if
indeed it ever did) that its employer (as regards its
in-house lawyers) or its client (as regards Bond Pearce)
is one of the SUBJECTS of this investigation. It is
equally clear that the Post Office Legal Team does not
accept that any influence that it exerts on us should
be, as it were, ‘light touch’ unless ratified by the
Working Group and by the other stakeholders (including,
of course, James). Instead, it is clear to us that Post
Office's attitude has hardened (from the Crichton era)
to one where we (Second Sight) are viewed as being under
contract/introductions to obediently follow our client's
(ie Post Office's) instructions as to what we are to
do -- or what we are to refrain from doing. It remains
unclear -- certainly to me -- whether the ‘lawyer tail
is wagging the Post Office dog' here or whether the
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in-house and external legal teams are doing the bidding
of the Board/Chairman/CEO. It may even be a combination
of the two. In either case, it has resulted in a wholly
inappropriate ‘Defend the brand at all costs’ stance
Just stopping there, do you agree with what
Mr Warmington there wrote?
A. Yes, I do.
MR BEER: Thank you.
Sir, those are only the questions that I ask
Mr Henderson. I know that there are questions from one
group of subpostmasters, which is through Mr Stein.
SIR WYN WILLIAMS: Yes.
Questioned by MR STEIN
MR STEIN: Good afternoon, Mr Henderson. As you may be
aware, I represent a large group of
subpostmasters/mistresses and people that worked in
branches of the Post Office.
I've got some questions to ask you about suspense
accounts, okay.
Now, you smiled, perhaps because this is an area
that we have been pursuing in questions for other
witnesses and it's an area whereby some of the answers
have been a little opaque; do you agree?
A. It's also an area where I believe we were sacked because
93,
A. Well, the reason we were interested in suspense accounts
was we needed to know to whom did the money belong?
Post Office was not printing money, it wasn't creating
money out of thin air. If there are any funds in the
suspense account, it was either going to belong to
subpostmasters or it was going to belong to clients of
Post Office, or at least those are the most likely
explanations. And I felt that we had -- we were aware
that there were substantial balances in suspense
accounts that were being taken to the credit of the
profit and loss account for Post Office and, therefore,
ultimately used to pay dividends, bonuses and everything
else.
I felt that there was at least a possibility, if not
more than that, that those funds belonged to
subpostmasters and may represent balances that -- and
losses that had been allocated to subpostmasters.
I felt we needed to get to the bottom of that and we
weren't able to.
Q. Can we go further up the page, please, and we'll see
then a draft response that was being considered. So if
we go up the page, we'll see that there's an email, if
we look at the date for this, we'll see it at -- you'll
see the bottom of page 2. We'll see it's from Andrew
Parsons, the date has moved on to 31 July, 2.47, and
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of our interests in suspense accounts. I think we've
got a mutual interest in this topic.
Can we take you, please, therefore, to a document which
is POLO0021762 and I'm going to take you to your -- it's
an email from your good self, at page 3, going into the
top of page 4. So if we scroll down a little bit
further we'll see, therefore, your email in its
entirety.
So let's concentrate on what we have here. You can
see that this is an email from you and the date is
30 July 2014, in the afternoon at 1.25. It is to
Belinda Crowe, copied to Mr Warmington, Angela van den
Bogerd, Mr Parsons, Chris Aujard, and the subject matter
is "Suspense account paper Second Sight". Okay?
Yeah.
So you say this:
"In the light of the disclosure of rolling 3-year
suspense account can we have details of month end
balances for this account for the last 3 years together
with details of amounts released to P&L", that's profit
and loss.
Okay?
That's the question being asked by you. Can you
help us understand why you were interested in this
particular point at that particular time?
94
then we see the body of the email at page 3, at the top.
Okay?
Yes.
So, again, this is Mr Parsons, recipients that are set
out here, Belinda Crowe, Angela van den Bogerd:
"Belinda, Angela ..."
What's being said there by Mr Parsons is that he
suspects that:
".., the information requested by lan [that's you]
below is highly commercial sensitive.
"It may also be that the figures in question are
quite high and this may then be portrayed as if there
are significant sums each month that cannot be
reconciled within [the Post Office's] accounts. The
inference from this is that [the Post Office's]
processes/accounting systems are flawed given the volume
of discrepancies. Whether or not this is correct, it is
an easy leap to make."
Then he sets out he's penned out a short response to
you below. You can see there that he's suggesting that
this may be a way of dealing with your question and the
proposal was to tell you:
"The information you are seeking is highly
commercially sensitive and therefore would only be made
available in exceptional circumstances.
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"As described in the Suspense Account Note provided
to you, sums in POL's suspense account do not impact on
branch accounting but reflect unresolved matters between
POL and its clients."
Now, as far as we know, this particular draft
response was never sent to you. Can you just help us
and see whether you agree with what was being written by
Mr Parsons:
.. sums in POL's suspense account do not impact on
branch accounting but reflect unresolved matters between
POL and its clients."
Do you accept that would be right or not?
It may be right but, equally, it may be wrong. I felt
the most likely explanation -- bearing in mind that
losses were being allocated to subpostmasters, I felt
that the most likely explanation was that, ultimately,
those suspense account balances were connected with
losses that were being allocated to subpostmasters.
Following on from that, if we can work out what the
effect might be of being able to analyse shortfall money
going into suspense account, would it also be a way of
looking at the overall integrity or operation of the
Horizon system, in other words a kind of canary in the
coalmine?
It's possible but, equally, I mean, suspense accounts
97
subpostmasters' money --
Yes, to the credit of their profit and loss account and
being used to pay bonuses and dividends.
Now, if we just continue with the email chain, we'll see
this is carried on in discussion within the Post Office.
If we go up to page 2, please, you'll see there that,
from the top, from Belinda Crowe, 1 August, to Charles
Colquhoun, Rod Ismay, Belinda Crowe, Angela van den
Bogerd, Rodric Williams, "Suspense account paper Second
Sight". The first part is:
"Second Sight have now come back on the paper and
asked for information on the suspense account."
It goes on to say this:
"Charles had previously suggested providing
a ballpark figure, but if we do that we would have to
wrap a significant amount of information around that as
context. However, Andy Parsons has sketched out
a suggested response below [and you and I have just gone
through that, Mr Henderson]. I do not know whether the
published accounts give any details or whether we do
ever make this information otherwise available but
I would be grateful for advice on how best to respond."
Going on to say:
"I think that we should consider this through the
lens of an FOI request and how we would respond to that.
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are a feature of modern commercial practice. Most
companies will operate suspense accounts. However, most
organisations will ensure that those balances are
reconciled and resolved within a very short period,
typically one to two days. What we were finding was
that very substantial amounts -- and I think I'd set out
a table in my witness statement that showed that, in
some cases, hundreds of thousands of pounds were being
held in suspense accounts for periods in excess of six
months. I mean, that is very poor accounting practice
and, as I said, I was concerned that at least those --
part of those funds should have been reallocated to
individual branch accounts.
What would be the alternative, if there was -- let's
say, using a figure you've just mentioned, maybe
£100,000 or so in a suspense account, what would be the
alternative or better alternative to putting it in
profit and loss account?
Analysing it properly and making sure that you didn't
carry forward balances in a suspense account more than
two or three days, which, as I said, is normal
commercial practice by most organisations. It was very
poor accounting, at the end of the day.
From what you're saying it also carries with it the
danger that, essentially, the Post Office is taking
98
Anyone could ask the question (and may have done so in
the past) therefore we need to be sure that whatever
response we give would not result in less information
being released than if they requested the information
under FOIA."
Then it refers to Second Sight producing a draft
report.
This discussion then continues and, if we go to
page 1, we'll see as far as we get to by 5 August 2014.
You'll see that, in fact, at the very top, it's 6 August
but let's go to the one on 5 August, just at the top
two-thirds of the page.
From Belinda Crowe, date 5 August 2014 to Charles
Colquhoun, Belinda Crowe, copied to herself, it looks
like, probably another email address:
"Charles
"As discussed. Here's Rod's email [probably Rodric
Williams].
“If you could send it to Rod and get an answer."
Then we see what's being said there:
"Belinda I agree with Andy -- I'd like to avoid
giving anything if at all possible (less is more), but
if we do, rather than give them the data they've asked
for, we should provide MI which gives context ..."
"MI"?
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Management information.
"including:
"rather than raw three-year data, give the monthly
average over the past 3/5 years;
"what that figure is as a proportion of total month
ending transactions; and
“average time to clear sums in suspense."
Then gives:
"eg something along these lines: 'The amount held in
suspense accounts across the Post Office network
averages £XX per Trading Period", so it then sets out
the potential draft response.
So just going through what was being discussed at
that stage within the Post Office, "I'd like to avoid
giving anything if at all possible (less is more), but
if we do, we can provide the information which includes,
rather than raw three-year data giving the monthly
average over the past three to five years"; would that
have helped answer your question?
No, I don't think so. I mean, we wanted to know the
detailed breakdown of the balances held by the suspense
account down to individual transactions and what they
are proposing here is not that. I don't think we would
have been able to tell whether or not we could link it
to individual branch accounts.
101
"As you will see, I really need someone from your
team who is technically switched on re suspense
accounts, and can handle themselves in front of
an adversarial audience.
"As you can imagine, I am concerned that we give
Second Sight no more information than is necessary to
address the narrow proposition that money that is
‘missing’ from [a subpostmaster] account is somehow
taken into our suspense account and then appropriated to
‘our [profit and loss].”
Now, this is not an email that you would have seen
at the time. Can you help us with your view on what's
going on here and the way that this is being discussed?
Well, Chris Aujard, as we've previously discussed, had
protection of Post Office at the centre of most of his
activity. Al Cameron was the newly appointed Finance
Director in January 2015, who I think, perhaps, shared
our view that we had asked an interesting question and
could see perhaps some merit in getting an explanation.
But that was being resisted by, certainly, the Legal
Team within Post Office.
To this date, today, where have we got to with suspense
accounts and the answer to your questions; have we got
answers?
We never got a detailed answer. I mean, we know that
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Q. Then “what that figure is as a proportion of total month
end transactions and average time to clear sums in
suspense", again?
A. Again, that's taking it away from the level of detail
that we'd asked for. It's a cover-up, again.
Q. Now, I'm going to take you forward in time, please, to
another email, an internal email, from Mr Aujard who you
have discussed already with Mr Beer. This is an email
from Mr Aujard to Alisdair Cameron, dated 16 January
2015, it is POLO0040805. Page 3 of 4. So POL00040805.
SIR WYN WILLIAMS: = Mr Stein, while that's being put up, was
there a reply to Mr Henderson's or Mr Warmington's
request in the email chain at all?
MR STEIN: Not that we're aware of, sir.
SIR WYN WILLIAMS: Fine. Okay. Thank you.
MR STEIN: Mr Henderson, can you clarify the answer to
Sir Wyn's question?
A. Not that we saw, I don't think.
SIR WYN WILLIAMS: — Right, thanks.
MR STEIN: Thank you, sir.
So we should have on the screen a document I've just
been discussing, page 3 and 4. You see at the top there
from Mr Aujard, date 16 January 2015, to Mr Cameron?
The request from Mr Aujard to Mr Cameron is this,
I'l read the second paragraph:
102
hundreds of thousands of pounds were taken into the
profit of Post Office that could have been related to
individual branch accounts and losses that were paid by
subpostmasters. I felt it was a huge mistake that it
was not investigated at the time when we first raised it
and, of course, investigating events that took place,
you know, 10 years ago is much harder now than it would
have been at the time.
MR STEIN: Excuse me one moment, Mr Henderson.
Thank you, Mr Henderson.
SIR WYN WILLIAMS: I Is that it, Mr Beer?
MR BEER: Itis, subject to one thing, and I've realised
that I omitted to ask Mr Henderson something.
SIR WYN WILLIAMS: Yes, by all means.
Further questioned by MR BEER
MR BEER: Thank you.
It was something I was going to ask Mr Warmington
and, just for completeness sake, I think I should ask
you too, Mr Henderson. It's an issue which the Inquiry
has been pursuing and is of interest, in particular, to
the counsel team and to the Chairman.
It's the Jenkins advice, Simon Clarke's Jenkins
Advice of 15 July 2013. Can we look, please, at
POL00006357. You've been provided a copy of this
document in order properly to prepare for your evidence
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session today, Mr Henderson. If we look at the last
page of the document, which is page 14, and just scroll
to the bottom, we can see this is signed off by
Mr Clarke on 15 July 2013, he being a barrister at
Cartwright King Solicitors. This advice addresses the
position of Gareth Jenkins and his reliability as
awitness.
When did you first see this document?
A. I think only very recently. I don't recall seeing this
at the time that we were working for Post Office.
Q. Gareth Jenkins was providing evidence to you and
information to you in the course of your
investigations ~
Yes.
-- and you were in part relying on what he was saying?
Yes.
prop
You told us earlier that you didn't know that he had
previously been used as a witness to give evidence about
Horizon in criminal prosecutions?
As an expert witness, yes.
Q. Yes. As a witness at all, I think, is that right? You
didn't know --
A. I think both are true. Yes.
Q. Yes. I think it must, therefore, follow that you were
not shown a copy of this advice at the time because this
105
>
Office's attitude towards him changed.
So that was in, we saw, the first telephone conference
in July 2012 --
Yes.
2
-- and then your meeting with him in September --
September, yeah.
-- 2012.
So, at that time, he was not a discredited witness, as
far as I'm aware.
rPOoOPrPO>P
2
Did you have any subsequent meetings with Mr Jenkins?
We had email contact. We didn't have any further
meetings. We may have had the odd phone call.
Q._ Inany event, you were raising your concerns with the
Post Office about possible miscarriages of justice -
A. Yes.
Q. -- and the Post Office were in possession of this
document but didn't describe the substance of it to you?
A. Correct.
MR BEER: Thank you.
Sir, I think that is all of the questions.
Questioned by SIR WYN WILLIAMS
SIR WYN WILLIAMS: Just one from me, really, and, again,
it's just to see if you do know anything. In the
Interim Report which Second Sight produced, I believe,
on 8 July 2013, there is reference to what I will call
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would have revealed that he had given evidence before as
a witness?
A. Correct.
Q. You were, I think, looking at files that included the
Seema Misra case; is that right?
A. Yes.
Q. This advice specifically addresses the evidence given by
Mr Jenkins in the Seema Misra case. Do you think you
‘ought to have been shown the advice?
A. When I was looking at the files held by Post Office,
I expected those files to be a complete record of the
documents that were relevant to the matter. So I would
expect the Clarke Advice to form part of that case, yes.
Q. Aside from being shown the document itself, did anyone
from the Post Office convey the substance of the Advice
to you, ie that Mr Jenkins was described as
a discredited witness who couldn't be relied on in any
criminal proceedings?
A. Well, I think we need to look at the timing quite
carefully. At the time that I was dealing with Post
Office and Simon Baker, Gareth Jenkins was being
represented as the Fujitsu expert and the go-to person
that Post Office routinely dealt with. That's why Post
Office introduced me to him and facilitated that
meeting, It was obviously after that time that Post
106
bugs. Can you tell me, Mr Henderson, how it came to be
that you got that information?
‘A. I do recall that, shortly before we published our
Interim Report, Simon Baker, again on behalf of Post
Office, did disclose some late information to us that --
of certainly two, if not three, types of bug that we
were previously unaware of.
SIR WYN WILLIAMS: Was that disclosure by Mr Baker done
orally or did he send you a document setting it out, so
to speak?
A. He sent us -- I mean, it was both. We had a lot of
telephone contact with him but he also disclosed those
documents to us and we referred to them in our report.
‘SIR WYN WILLIAMS: All right. Thank you very much.
So I think that concludes your evidence,
Mr Henderson. I'm very grateful to you for
participating in the Inquiry by both providing
a detailed witness statement and by giving oral evidence
this morning and into this afternoon. Thank you very
much.
THE WITNESS: Thank you, sir.
‘SIR WYN WILLIAMS: So what time shall we resume, Mr Beer?
MR BEER: 1.55, please.
SIR WYN WILLIAMS: Fine.
MR BEER: Thank you.
108
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(12.54 pm)
(The Short Adjournment)
(1.55 pm)
MR BEER: Good afternoon, sir, can you see and hear us.
SIR WYN WILLIAMS: Yes, thank you.
MR BEER: May I call Ron Warmington, please.
RONALD JOHN WARMINGTON (affirmed)
Questioned by MR BEER
MRBEER: Good afternoon, Mr Warmington. My name is Jason
Beer and I ask questions on behalf of the Inquiry. Can
you give us your full name, please?
A. Ronald John Warmington.
Q. Thank you, you've made two statements to the Inquiry,
the first 54 pages long and the second 12 pages long.
Can we look at the first, please, it's dated 20
May 2024, WITN01050100, and I think there's a correction
you'd like to make on page 20; is that right?
A. That's right, Mr Beer. There's a sentence, the very
first sentence at the top of page 20, which starts with
“not only" and finishes with the word "integrity". I'd
like to remove that. It was mistaken.
Q. Thank you. Then if we go to the last page, please,
which is page 54 --
A. Yes.
Q. ~is that your signature?
109
which I would have taken from your witness statement.
A. Right, my --
Q. Oh, you're quite right. '66. My fat fingers! In any
event, it was a company that was subsequently acquired
by Emst & Young?
A. That's right.
Q. Between 1975 and 2002 you worked for Citibank; is that
right?
A. Yes.
Q. Variously as a Regional Head of Internal Audit, Chairman
of the Audit and Risk Committee, CFO, Head of
Investigations for Europe, the Middle East and Africa,
and then Global Head of Investigations?
A. That's right.
Q. Between 2000 and 2010, you were a Director of GE Capital
as Head of Fraud Management in Europe, the Middle East
and Africa?
A. Yes.
Q. In 2009 and 2010 you became part of, and then a director
of, Second Sight Support Services Limited?
A. Yes.
Q. Thank you. Before we get into some of the detail, can
I seek to explore with you at a higher level the issues
that are raised in your witness statement, so a summary?
A. Mm-hm.
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Itis.
Including the correction you've just made, are the
contents of that statement true to the best of your
knowledge and belief?
They are.
Thank you. Can we turn to your second witness
statement, please, which is dated 10 June 2024,
WITN01050200. Is that your signature on page 12?
Sorry, it's here. Itis.
Are the contents of that witness statement true to the
best of your knowledge and belief?
They are.
Thank you very much. Can we look at your background to
start with, please. I think you became a chartered
accountant in 1971; is that right?
That's right.
In 1979, you became a Fellow of the Institute; is that
right?
Yes.
In terms of your work career, you worked as an external
auditor between 1968 and 1975, for a company that was
subsequently acquired by Ernst & Young; is that right?
I think it was from 1966. September '66 onwards. Have
I made a mistake somewhere?
I don't think it matters. I've got in my notes '68,
110
To summarise, is this right, you were an independent
forensic accountant contracted by the Post Office to
conduct an investigation into, broadly speaking,
Horizon?
Yes.
You had the backing of MPs, who were trying to get the
Post Office to address their concerns, ie the concerns
of MPs raised on behalf of constituents?
Yes.
In the course of your work, you had access to senior
people within the Post Office, who either themselves had
access, or could access, information concerning issues
with Horizon --
Yes.
-- and could access information about criminal, civil
and disciplinary action taken against subpostmasters?
That's correct.
According to your statement -- no need to turn it up,
it's paragraph 22 -- you initially received clear
promises of cooperation, assistance and unrestricted
access to whatever documents you might call for?
Yes.
Those promises were made by Susan Crighton, Paula
Vennells and Alice Perkins?
That's right.
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Despite this, you tell us in your witness statement, you
found that the Post Office reneged on those promises?
Yes.
By withholding documentation and information from you?
Yes.
By failing to provide proper answers?
Yes.
And you eventually formed the view that the Post Office
considered that Second Sight was "entirely under its
control and could be ordered to do or could be
disallowed from doing whatever it, the Post Office,
wanted"?
Yes, that was clearly their position and view; it wasn't
my position and view.
You say in your witness statement that you experienced
the Post Office's strategy of denying problems that it,
the Post Office, knew of?
Yes.
Of trying to remove oversight or investigation which may
have led to adverse conclusions about Horizon in
particular?
Yes.
At the time you were doing the work, did those thoughts
occur to you?
Oh, yes.
113
two, or so, years’ work?
I'd say right from the very outset. I warned Post
Office top brass of that possibility from day zero.
In terms of what you say in your witness statement about
the promises of cooperation, assistance and unrestricted
access being reneged on, when did that start to occur?
Difficult to put an exact date on it. It must have been
probably about February 2013. As early as that, within
months of us starting work.
The Inquiry has seen a number of internal Post Office
documents that show that, at least in 2013, individuals
within the Post Office were contemplating minimising the
role of Second Sight or ending the role of Second Sight
completely. You've described in your witness statement
a “ferocious pushback from the Post Office" during your
investigation. Do you think there was ever a time when
the Post Office staff were cooperating with your
investigation fully?
Oh, yes. Initially. The response from Susan Crichton
and from Simon Baker, the young IT expert that was
assigned to help us to get access to data attitudinally,
had exactly the right -- they definitely shared or
appeared to share our objective of seeking the truth
regardless of consequences.
What caused the ferocious pushback?
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This isn't after the event?
Oh, most certainly not.
At the time you were doing the work, why did you think,
it, the Post Office, was conducting itself in this way?
Well, very much along the lines of what Mr Henderson
said: that it was very clear that Post Office knew --
insofar as a corporation can know anything -- the people
at the top knew that they were dealing with
an existential issue, that, if it turned out that
Horizon was generating spurious shortfalls, that they
had a lousy investigation function, that they had
wrongfully prosecuted people. That would be
existential.
In what sense would it be existential and why? What
were the stepping stones?
Well, the need to rely on the integrity of Horizon in
order to be able to, if you like, control the network of
subpostmasters, their agents. To be able to exercise or
to carry out that sort of level of control, to have it
known that the Horizon system was unreliable, or that
the supplier of the Horizon system, Fujitsu, or that the
user of it, the purchaser of it, Post Office, was -- it
could not be relied upon, would mean that all hell would
break loose in the branch network.
Was this a view that you formed in the course of your
114
I think when they started lawyering up. It was pretty
clear that, as soon as lan came to me and said, "Look
what I've found, I'm finding some really odd stuff in
these legal files and we" --
Stopping there, when was that?
It was very early on. Again, I would say it was during
August 2012. I may be mistaken but it was very early
on.
What was the “odd stuff" that lan was finding?
Well, you've looked at it earlier today, the Brander
report, and considering he was only looking at a dozen
or so files, and we knew there were cases behind that,
it was giving very clear evidence of what I saw or we
saw as wholly inadequate investigation work.
One of the accusations that is levied against Second
Sight very frequently in the internal Post Office
material, and it sometimes breaks out into things said,
for example, to James Arbuthnot and then subsequently to
Sir Anthony Hooper, is that one of the chief problems
with your investigation was the slow pace at which it
was proceeding. Was that a view that was expressed to
you at the time?
Yes, it was.
Was there substance in the view?
Yes. It was taking longer, particularly in the --
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during the Mediation Scheme, with 150 applicants, each
with a very detailed story, and the need to wait for
evidence to be produced by Post Office, which was taking
much longer than we that ever expected it to.
What was the cause of the delay, firstly in the initial
investigation, ie up until the Interim Report of 8 July
2013?
Well, part of it, I think, Mr Beer, was because Post
Office -- this is not unusual in big companies -- Post
Office seemed to be excessively siloed with different
departments, each of which would have some but not all
of the information and so, gathering in the information,
which Simon Baker was helping us to do, just proved to
be like swimming up a waterfall. It was really, really
difficult to get the information, and that slowed --
that was -- I'm not trying to shoulder duck the issue or
pass off blame, but getting the data to us to be able to
reach any conclusions was taking an inordinate amount of
time.
If we turn up paragraph 41 of your witness statement,
please, which is at page 18, it'll come up on the screen
for you.
Yeah, sure.
Page 18, foot of the page. You're here in the Mediation
Scheme, and you say:
117
help us with, without specific examples, but what you're
talking about there "monstrous pushback" and "illogical
pushback" on sentences used in your reports?
Yes, I mean, it was constant. So -- and much of it
revolved around what Post Office was asserting, with
some justification, was inadequately evidenced remarks
that we were making. A good example of that would be in
connection with the contention by many of the
subpostmasters that they'd never seen a copy of their
114-page contract prior to sort of running into the
barbed wire fence in legal action some years later. And
Post Office was saying, "Well, hang on a minute, you
can't -- you're just spouting anecdotal evidence given
to you by a few postmasters", and my reaction was,
"Well, hang on a minute. I can't provide evidence of
that because I have yet to see a contract that has been
signed and dated by a subpostmaster". And then we were
getting the -- what became almost like a mantra of the
Post Office's position is that "We would have, our
procedures would have ensured that this had happened".
Similarly, when I was trying to get across the
point, this -- this is one of scores of points -- that
the postmaster -- that risk had been transferred on to
the postmasters' shoulders without their acknowledgement
or, for that matter, knowledge, on matters like the
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"Where we couldn't resolve a point of a conflict
within a report, we would flag it in the relevant place.
An example of a conflict within a report would be the
issue regarding Fujitsu's Bracknell office (ie [the Post
Office] denying that Michael Rudkin had ever arrived at
the meeting that he said he had been invited to).
I encouraged Michael to search through his emails to
locate the original invitation which, fortunately, he
found. I had requested this email from [Post Office]
multiple times, but they said they could not find it.
It was this kind of pushback that meant that our CRRs
[Case Review Reports] went through multiple drafts,
sometimes five or more. I had never before encountered
such ferocious and determined pushback from a business
or client. I was very used to dealing with conflict in
my profession but had never encountered such ferocious
resistance to almost every sentence used in every
report. Every point we raised, that we knew to be true,
received monstrous and illogical pushback. Their
approach was, in my experience, unprecedented,
particularly during the drafting of our final report and
many of the [Case Review Reports].”
You've given one example there of Mr Rudkin seeking
an email that might have confirmed his presence on
Fujitsu's premises in Bracknell, as he said. Can you
118
doing away with paying-in slips, or the fact that they
no longer had any local record of cheques that had been
sent in for processing and might turn out to be mangled
and totally shredded in the cheque-clearing machines,
the cheque-processing machines -- matters that
ordinarily I would have had zero difficulty in
communicating in conversations like this, just seemed to
be beyond the ken of people in the Post Office.
And at first I was taken in by that; later,
I wasn't.
When you say you were "taken in” by it, what do you
mean?
I took it at face value. I took it that I was pretty
pathetic at explaining points and had lost the knack of
explaining things simply. But, eventually, I twigged
that, in my judgement -- I may be wrong -- it was
feigned ignorance, not real.
Did the Post Office seek to influence the drafting of
your final CRR reports?
Oh, yes.
How did they do that?
Well, by examining every word, every phrase, every full
stop and comma. Again, I -- I mean, we made a point, my
entire team made a point of writing things with extreme
clarity. We checked for that. So it was unusual to
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have any report that wasn't completely clear and, yet,
Post Office seemed to find reason to challenge just
about everything we said.
Did you adapt the words used, the language used, in the
reports, the CRRs, as a result?
To adegree. You probably realise that Mr Henderson and
I, and in fact our colleagues, are not easily -- not
necessarily for turning. So there were some pretty
intense scraps but we obviously listened to and tried to
accommodate the changes they were requesting and
certainly, where we'd made mistakes, we corrected them.
In his witness statement, Mr Henderson said at page 22,
paragraph 71, said:
"To the credit of the Post Office, they [the Post
Office] did not try to directly to interfere with or
influence Second Sight's reports other than by
withholding potentially relevant documents."
That's slightly different from what you're saying
now, that there was an attempt to interfere with or
influence the language used.
Yes, there is a little bit of difference there. I mean,
I was involved in a lot more of what lan himself would
have referred to having been down in the weeds and
dealing with a lot of the accounting issues in minute
detail, and so I probably encountered a lot more
121
"We in Second Sight, held the view that those
concerns, that had been so clearly expressed by the MPs,
and their equally clear expectation we would be
investigating them, had certainly not gone away but that
‘our Interim Report was to focus, in the main, on the
narrower issue of 'systemic flaws in Horizon’. The
inference -- and our understanding -- was that the
original, far wider, scope had never simply vaporised,
and that we were still expected (by the MPs and by the
JFSA) to address them. On reflection, it would have
been helpful had we included words to that effect in our
Interim Report, although it seems now to be pretty
obvious that [the Post Office] would have fought hard to
avoid conceding that. It is now clear that the Post
Office really had hoped that, after Second Sight's
Interim Report, that wider scope investigation would
simply never happen.”
Mm-hm.
Can we just look at your Interim Report, please.
POL00099063. This is the Interim Report of 8 July. Can
we look at page 8, please. Paragraph 8.1:
"This is an Interim Report and there is much work
still to be done."
At this point, what in your mind was still to be
done?
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pushback than he did, although he was encountering
pushback on matters to do with the evidential quality.
I was going to ask you: what was the division of
responsibilities between you and Mr Henderson?
Well, he's better than I am, so, I mean, he got the
difficult stuff to deal with. Essentially, it was
pretty obvious. lan is a specialist in documentation,
computers, evidence handling and also he was living in
London, I wasn't. It made sense for him to be onsite at
Old Street, whereas I was haring around the country
making face-to-face contact with the subpostmasters,
which, of course, I'd been asked to do by James
Arbuthnot and his colleagues.
So it was very clear that -- and I omitted to
mention that, of course, lan had had that very valuable
experience with the CCRC. So I had far less knowledge
of criminal procedure than he did but neither of us put
ourselves forward as lawyers.
Can we move --
I hope I answered the question adequately?
Yes, you have. Can we move forward, please, to
paragraph 58 of your witness statement, which is on
page 28, the foot of page 28. You're here dealing
with -- at about the point of publication time of the
Interim Report, and you say:
122
Well, lan referred to this earlier. We -- colloquially,
we had come to regard the work that we were doing as
what we called Job 1 and Job 2. In fact, that
terminology was accepted by Post Office. Job 1 was the
broader investigation that definitely included
consideration of the conduct of investigations and
prosecutions but this -- this was narrower and, as we
went into the Mediation Scheme, that became a more
narrowly defined piece of work, which we referred to as
Job 2. The reason we called it the Interim Report was
because it was an Interim Report.
In your witness statement, you describe things the other
way round: that the narrower piece of work was Job 1, it
focused, in the main, on the narrower issue of systemic
flaws in Horizon. Why was the narrower issue the issue
of systemic flaws in Horizon?
If that's what I've said, Mr Beer, I've got it the wrong
way round because Job 1 was, unsurprisingly, the first
piece of work which the MPs had asked us to do. The
narrower job was -- manifested itself principally in the
Mediation Scheme, which was under way at this point.
Let's look at your witness statement alongside this
then, please.
Yeah, I -- may have got it wrong.
It's page 28 of the witness statement.
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You may have caught me out.
Page 28, paragraph 58 at the bottom. I'll read the
whole sentence:
"We, in Second Sight, held the view that those
concerns, that had been so clearly expressed by MPs ...
had certainly not gone away but that our Interim Report
was to focus, in the main, on the narrower issue of
‘systemic flaws in Horizon’."
Well, I have expressed that the way I intended to, but
I think the confusion which I've allowed to creep in
here, for which I apologise, is that the Post Office's
understanding of the Mediation Scheme was that that, in
a sense, displaced/vaporised the original work that we'd
been asked to carry out, and we did not share that view.
We, as far as we were concerned, the initial request by
the MPs, which involved "taking the JFSA along with us",
had definitely not gone away but Post Office completely
disagreed with that position.
So without reference to the documents, then, if I can
just try and get an understanding of it, it was your
view that there were always going to be two pieces of
work: Job 1 and Job 2?
Yes.
That the first of those, which is reflected in the
Interim Report, focused on the existence or
125
Complaint and Mediation Scheme, what was still left
after the production of the Interim Report?
Well, had the Mediation Scheme not fired up and diverted
our attention onto the 150 applicants’ is it cases, we
would have continued to do the work that the MPs had
asked us to do and which had been covered in my original
proposal of work, which had never been other than
acknowledged. There that never had been an initial
letter of engagement.
So all of the other issues raised by the MPs on behalf
of their constituents still fell to be addressed?
Yes.
The Post Office determined that that should be done
through the Mediation Scheme?
Yes.
At the time, was it your view that that was
an appropriate means of addressing those issues?
Yes, seemed like a good idea.
Why did it seem like a good idea?
Well, I think it was -- I mean, at that point Susan
Crichton was still involved and still -- there still
seemed to be this persuasive search for the truth, and
it involved seeking applications from the entire
network, and we wanted to get cases that could be
efficiently or even at all investigated and, getting
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non-existence of system-wide or systemic problems with
Horizon?
Yes, Mr Beer, but I think the point that has been
confusing everybody is that Job 1 was actually very
broad but that the Interim Report was not -- it probably
should have been but it was not an attempt to answer all
of those broad questions that had been posed by the MPs.
At that point, we'd been asked to just produce a report,
the Interim Report, on these narrow issues --
Okay.
-- which was, you know, probably absurd and we should
have said no.
I was about to ask. Was it a request of the Post Office
that led to the production of the Interim Report?
Yes.
Why did Second Sight agree to it?
Well, because it wasn't just the Post Office that was
communicating that. The MPs were getting quite --
"irritated" wouldn't be too strong a word, that the
investigation had been chuntering along for a year at
that point and there didn't seem to be much output from
it. So at least we should produce a report that said
something, and so this narrow request was agreed upon.
I see. In your mind, putting aside the events which
happened, namely the development of the initial
126
newer cases, where the data was more likely to be
available still, was clearly going to be a good thing.
This conclusion at 8.2(a), on the right-hand side:
“Our preliminary conclusions are:
"We have so far found no evidence of system-wide
(systemic) problems with the Horizon software ...’
On the investigation of how many cases was that
preliminary conclusion formed?
I think it was about 50/49, something like that. We
had, I think, 29 cases from the MPs, 18 from the JFSA,
that's 47 by my counting. So I think it was based on
those. But, of course, we'd narrowed that down. We had
to, because we -- investigating 49 cases right across
the detail wasn't feasible, so that's where I think lan
came up with the good idea of spot -- what we called
spot reviews: just focus on events within a case and dig
into those.
Is it right, therefore, that that conclusion is based
ultimately on the examination of four cases?
I think, by that point, we had about -- we had
20-something spot reviews but only four of them had
really been bottomed out and, even then, one of them was
Spot Review 5, the Rudkin matter, which hadn't been
bottomed out. So there were still lots of unanswered
questions as we wrote this.
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So that preliminary conclusion was reached on the basis
of the four cases that had been investigated the most --
Yes.
-- one of which was still incomplete?
Yes.
Do you think, on reflection, that ought to have been
made clearer in paragraph 8.2(a), so that it might not
be misused or misappropriated by others for a different
purpose?
Well, with the benefits of hindsight, absolutely.
I wish we'd said that. I think lan mentioned earlier,
it would have been probably better if we'd spelled out
exactly what we meant by "systemic". We didn't use the
word by accident and a considerable amount of thought
and discussion went into the word we used there. But,
with the benefit of hindsight, Post Office pounced on it
and, as lan said, trumpeted it from the rooftops, and
Alan had warned us that that would happen.
Before you wrote it or afterwards?
Oh, before, because of course he was entitled to and was
seeing the drafts of these documents. I think he saw
the draft of this. Certainly, he'd -- Sir Alan, as we
all know, pretty astute, and I think he was -- he
foresaw better than I did the danger of this.
Can I look at something that you later said a year and
129
you say here, systemic errors had been disclosed to you
by that time?
Mm, it is contradictory, I see the point, and probably
not very wise wording at the time. Let me clarify.
"Systemic", to us, meant that this was something that
was occurring right through the network of the
12,000-odd branches, and, had there been such systemic
bugs, they would have been glaringly obvious to at least
some of -- quite a lot of the people. That was the
opposite of what we'd found.
What we found was that the -- whether it was bugs or
other forms of error and defect that were manifesting
themselves were unusual, were rare, but had
life-changing impact on those that the bugs hit, but
were inconsequential in the context of the entirety of
the system.
So Mr Cameron -- Al Cameron, was one of the few
witnesses that's referred to the comparative impact, the
materiality of events that, in Post Office's world, are
immaterial but, in the individual cases, are hugely
material. And so I guess I'm still, in this transcript,
probably still being a little bit muddle headed into the
use of the word "systemic". I wish we'd never used it,
you know. We did, we used it advisedly, we gave it
a lot of thought but it led to such abuse that I wish
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a half later about this in a call that you had with Tim
McCormack, just to explore what was meant here and what
you thought this conclusion was meant to represent. Can
we look, please, at SSL0000126.
This was a recording or a transcript of a recording
that I think you made with Mr McCormack on 26 October
2015.
Yes.
If we go to page 3, please, and scroll down, please.
It's that section there. You say:
"You know, should [anyone] be surprised? Of course
there are bugs in the system. Now, we were at pains,
you probably are aware, in that, when we released that
Interim Report, we studiously avoided using the term
that there had been 'systemic errors’, even though there
had been some disclosed to us. We steered [clear] from
that. We have now -- I've made it clear in emails to
Cameron, Freeman, the Minister herself, we are now of
the view that, not any did systemic bugs exist during
the time of these cases arising, but that systemic bugs
in all likelihood definitely still exist."
Then you carry on. The point there "we studiously
avoided using that term ‘systemic errors’, even though
some had been disclosed to us", why did you avoid using
the term "systemic errors” in the Interim Report if, as
130
we'd used a different form of words.
Thank you. That can come down. Can I go right back to
the beginning, then, the initial instruction of Second
Sight. You describe this in your witness statement, if
we can turn it up, please, at paragraphs 15 and 16,
which is on page 8. You're here referring to
a PowerPoint proposal that we've seen many times, I'm
not going to go into it, but you say, by reference to
that PowerPoint proposal:
"I suggest that no reasonable person could possibly
have failed to understand that the review envisaged in
my proposal was intended to address the possibility of
prosecutorial misconduct."
Just stopping there, you're saying that a matter of
plain language and fair reading of the document?
Oh, yes.
You go on to say:
“Indeed, we had been informed that this was the
primary focus of the MPs who had brought pressure to
bear on [the] Chairman and CEO to carry out a review."
Stopping there, does that sentence reflect the fact
that the MPs were not concerned with whether there were
intricate or arcane coding problems in the Horizon
system; they were concerned that some of their
constituents had been wrongfully prosecuted?
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Yes. The simple answer to that is yes. The one or two
of the MPs expressed, as the Inquiry has already heard,
a desire to sort of carry out some sort of deep code
review and we'd said it's going to be difficult to do
that. You need to find exactly which piece of software
existed on a particular date but the short answer to
that question was that -- it was crystal clear that all
of the MPs, their primary concern was that there'd been
prosecutorial misconduct.
You say:
"In due course, as we met [them], it became crystal
clear that this indeed was their primary concern."
Yes.
In 16, you say:
"I have subsequently learned, on reading a two-page
email [of] 6 June 2012 [you hadn't previously seen it],
that Susan Crichton had summarised [your] PowerPoint for
Paula Vennells. [It] is largely a cut and paste from
[your] PowerPoint, with relatively few changes. Having
now read that email, I am even more shocked than I was
when, as early as May 2013 and thereafter, Paula
Vennells contended that Second Sight had never been
invited to look for any evidence of unsafe
prosecutions."
Was that something that was emphasised to you by
133
"I have just met Ron Warmington and want to put on
record that he would do an excellent job for us: exactly
the right quality level of engagement, etc, we're
looking for. I made it very clear to Ron that our
primary objective of this exercise is to be transparent
and to deal with whatever outcomes and conclusions he
comes to."
Does that fairly reflect the meeting that you had
with her in June 2021 (sic)?
Yes, it's a bit of an abbreviation of it, but yes.
An abbreviation in what sense? I mean, obviously this
is a minute of the meeting, it's the -- a summary of the
outcome?
As best I recall, she's probably referring to the
meeting where I sort of laid it on the line that there
were extraordinary risks associated with this search for
the truth and I might, although she might think me to be
a good choice, I might not be. That she might be better
off with somebody that would do things differently.
Did you receive any formal feedback on the PowerPoint
proposal that you presented?
Well, strangely enough, and I kick myself on this,
I don't think we did. It was just we said, "Look, we'll
initially, it was a very small job, seemed
to be a very small job. So we said we'll just proceed
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Paula Vennells?
Um --
That it wasn't part of Second Sight's brief, its terms
of reference, to look for evidence of unsafe
prosecutions?
Well, as a matter of huge regret -- and not only myself
but my colleagues at Second Sight -- that we had far
less face-to-face contact with Paula Vennells than
I would ordinarily have expected us to have, and that,
therefore, we'd been shunted down to the second level
of, as I say -- I think they called themselves conduits,
who were, as far as we were at first aware, were
conveying to us what Paula wanted and didn't want. So
I'm using a sort of shorthand there.
I now see from the material that I've read that
I hadn't seen before, that it's pretty clear that she
was pushing that, but we were getting messages from
Paula of Paula's intentions and desires through the
conduit of people like Aujard, Alwen Lyons, and others.
Can we look, then, at what her initial reaction was to
your proposals by looking at POL00180779. This is
an email you wouldn't have seen at the time. It's from
Paula Vennells, one of her staff, in fact, is sending it
to Susan Crichton, copied to Alice Perkins and Alwen
Lyons:
134
on a time and materials basis, and these days, of
course, we would have insisted on a proper contract and
a proper letter of engagement, and so on, otherwise, you
know, we'd be missing out. But it was just sort of "Go
ahead". I now know that, behind the scenes, there was
a considerable amount of debate on a sort of putting
together a letter of engagement but it was never
communicated to us.
After the meeting with Ms Vennells did you believe that
she meant what she said, rather -- namely what's
recorded in this email, namely the Post Office's
objective, primary objective, was to be transparent and
deal with whatever outcomes and conclusions Second Sight
reaches?
Now, call me stupid, but I believed that and I later
learned that probably wasn't the case. Well, I think it
probably was the case at that point. That was what she
conveyed, convincingly, and I accepted it.
Do you know why, or did you know why, the Post Office
appointed Second Sight over other forensic accountants?
Haha! As lan said this morning, we were cheap. We were
certainly, with fewer overheads and less greed. We had
a pretty good value for money proposition but I think
the driving factor was that Susan Crichton -- with whom
I've never played tennis, incidentally -- held a view
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that I had form for pursuing evidence of innocence when
people looked guilty and very, often finding that the
innocent had been or would have otherwise been fired or
worse for acts that they had not carried out themselves.
Was that in Citibank or at GE Capital?
Principally in Citibank. My role at GE Capital was more
sort of fraud management with an occasional
investigation thrown in, whereas in Citibank it was pure
investigations, often into the conduct of employees at
all sorts of levels right up to the top brass.
If we go back to your witness statement at page 9,
please, and look at paragraph 19 on page 9, you say:
"In due course, Second Sight was approved by alll the
parties and a decision was made, which we later came
deeply to regret, that although Second Sight's 'clients'
comprised the MPs and the JFSA as well ... the contract
would be between Second Sight and [the Post Office],
with no oversight by the MPs and only some ‘mild’
‘oversight on behalf of the JFSA, by Kay Linnell."
Why were you concerned when you learnt that Second
Sight was to be contractually engaged only with Post
Office, rather than all of the interested persons?
Well, it was very clear from the outset that the
subject, the principal subject -- or subjects of the
investigation were to be the postmasters, who may well
137
coming up with suitable candidates --
Yes.
-- because of your years of work in this field: is that
right?
Yes.
You brought in three further investigators; is that
right?
Yes.
Are those, or were those three investigators, Chris
Holyoak?
Yes.
Did he join the investigation in about February 2014?
Yes, I think shortly after he retired from his bank that
he was --
We've got a confidentiality agreement with him --
Yes.
-- dated 8 February 2014 --
Yes.
-- which would tend to indicate, if things were working
well, that would be the beginning of his engagement?
Yes, that was when we were realise that the two of us
wasn't going to cut the mustard.
Did Kim Evans join the investigation in about July 2014?
Yes.
Again, we've got a confidentiality agreement of 30 July
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have had their hands in the till, and Post Office. They
were the two parties involved, and perhaps Fujitsu. To
have the subject -- the principal subject of
an investigation also be the paymaster is absurd, and it
was Andrew Bridgen, as I say in paragraph 20, who was
the most outspoken on that point. He spotted that
problem right upfront and was very angry about it.
I mean, I -- we accepted that, the Treasury
apparently said, "We haven't got any money and,
therefore, Post Office is going to have to pay for it"
but it was a daft decision.
Was that explored at the time: the Treasury being the
paying client rather than the Post Office itself?
I don't think it was. I don't think it was -- Oliver
Letwin was representing the Treasury at that point and
his view was it's out of the question, Post Office is
going to have to pay for this. But they could have paid
for it through a conduit of the Treasury.
Thank you. That can come down. You say that it was
obvious from very early on that the number of cases that
you were expected to investigate was increasing and you
would, therefore, need to hire in additional
investigators, yes?
Yes.
You say that you and Mr Henderson had no difficulty in
138
2014?
Yes.
Lastly, Niall Young. Did he join the investigation in
about August 2014?
Yes.
So does that mean that, for the time up until the
publication of the Interim Report, there were the three
of you?
Yes.
Were there any attempts made to bolster your resources
in that time?
Not by us. I think the answer is no because, by then,
we knew how much had been invested in acquiring the
knowledge of what had been going on, and we recognised
that bringing anybody in, no matter how good they were
as an investigator would divert attention by lan and
myself onto bringing that person up the curve. It was
a bit of a Catch-22 situation.
The number of cases, I think, increased sharply from
around 10 in June 2012, at start-up --
Yup.
-- to 49 or so by February 2013; is that right?
Yes, that's right.
Did that pose resourcing problems?
Yes. Broadly.
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When you started the investigation, I think you were
struck by the lack of what you call a general file, is
that right -—
Yes.
-- to deal with already reported Horizon-related events;
is that a fair description?
It most certainly is.
What were you expecting to find?
Well, my experience as a corporate investigator meant
that, whenever broadly similar events occurred, whether
it was ATM shortfalls or fraud by customers, or
whatever, the Investigation Team would draw those cases
together, look for linkages, and help -- in order to
help its investigators get to grips with what
systemically had gone wrong to allow that fraud or that
event to occur. So you would normally have, you know,
a case management system that would draw things together
and then be searchable to say "What other cases have we
had involving motor vehicle licences or, for that
matter, that involved remittances in or out that have
gone adrift?" Ordinarily, you'd be able to say, "Yeah,
we've had 25 of those cases, let's have a lock if there
are any similarities", and that was completely absent.
It may sound a bit of a noddy question but why would you
expect an organisation in receipt of a series of
144
Yes.
News pieces, articles in The Grocer, Computer Weekly?
Yes.
Letters to the Sunday Times saying, "I have wrongly been
gifted £2,500 worth of Premium Bonds", that kind of
thing?
Most specifically including that kind of thing, yes.
Would it also include matters that had come up through
any form of Helpdesk that the Post Office or Fujitsu
operated?
Yes, that's a subject in itself, isn't it? The answer
to the question is yes.
Would it include reports on any bugs, errors or defects,
however they are described, that were found to have
caused or potentially caused balancing or other data
integrity issues?
In any company I've ever worked for, yes. Those sort of
things, all of the above, would be included.
When you were instructed, and in the absence of such
a compendium of material, were you, in fact, made aware
by the Post Office that there had been acquittals in
criminal trials of subpostmasters who had alleged that
Horizon was responsible for the shortfall of which they
were accused of either stealing or falsely accounting?
No.
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complaints or grievances or suggestions or allegations
to draw them together in a central repository for the
purposes of investigation and analysis?
Well, quite frankly, Mr Beer, it's hard to see how
an Investigation Team could deliver an effective service
to its employer without having that. So, you know,
being able to answer questions like, in the extreme, how
many people have committed suicide or attempted it, you
would expect that sort of answer to be available and,
less seriously, how many instances have we had of
customers who have said, "I got lucky, I got a windfall,
there's something gone wrong, I've had something for
nothing, I'd like to tell you about it"? There was
no -- you would expect there to be scores of those sort
of cases but to be told that there haven't been any is
just -- it's ludicrous. I hope that's an adequate
answer.
Yes, you're referring to a compendium, whether written
or electronic, that would bring together -- would I be
right -- letters from subpostmasters, reports, via line
managers or similar; am I right?
Yes, very much so.
Any court judgments --
Yes.
-- whether in favour or against the subpostmaster?
142
Were the names Nichola Arch, Maureen McKelvey, Suzanne
Palmer mentioned to you?
No, not at that stage.
Did the Post Office draw to your attention right at the
beginning any suites of documents held by the Post
Office concerning the functioning of, or deficiencies
in, the Horizon system, including release notes
documenting bug fixes?
No.
Major incident reports?
No.
Service Management documents?
No.
Did they, the Post Office, present you with
documentation -- and I include in that phrase memoranda
reports, emails, minutes of meetings -- concerning bugs
of which the Post Office was already aware, in
particular, the Callendar Square bug and the receipts
and payments mismatch bug?
No. First we heard of that was from Simon Baker in,
I think, May 2013.
Did the Post Office provide you with Jason Coyne's
report, prepared for the purposes of the case involving
Julie Wolstenholme in 2004?
No. I wish they had.
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Did the Post Office provide you with the BDO Stoy
Hayward report prepared for the purposes of the Lee
Castleton case in 2006?
No.
Did the Post Office provide you with any witness
statements that had been prepared in past cases of the
Post Office in criminal proceedings which set out
categories of documents including PinICLs, PEAKs and
KELs, that may be relevant to your investigation?
No.
Same question in relation to civil proceedings brought
by or against the Post Office?
No. The first we heard of civil proceedings was the Lee
Castleton case, which came up quite a bit later.
Did the Post Office provide you with any operational
change proposal records which set out the existence of
a facility for remote access and email correspondence in
which the Post Office approved Fujitsu remotely
inserting messages at a branch level?
No. First we heard of that was lan's discovery of the
Gareth Jenkins document while he was sitting next to
Susan Crichton and Jarnail Singh.
Did you discuss with anyone within Post Office "Why
haven't you got a general file, a compendium or a case
management system"?
145
the Post Office Investigation Department -- John Scott's
department. I'd like your views on more or less how
sensible that would be for me to do that. What are your
views on -- you know, can you write me a little report
outside of the main piece of work that you're doing, on
your observations about the Investigation Department?"
When was this prepared, roughly?
Ooh, oh, now you've got me on that. I think it was --
it must have been -- I would have thought it was like
August 2012. But it -I might be wrong on that. Is
there no date on this?
No.
Oops. Sorry.
Well, it's a draft, in fairness to you.
And it remained a draft. It was just really almost
a personal memo between myself and Susan, with caveats
as to its reliability. But it was pretty well straight
away. I remember she'd almost immediately been asked to
take over the department, and she was in some -- almost
trepidation might not be too strong a word about that.
"DRAFT Observations on the Investigations Function.
"What have we found out about [the Post Office's]
Investigation Function in reviewing the Case Files
during the Horizon Investigation?
"In reviewing [the Post Office's] documentation
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Absolutely, with Susan Crichton.
What was the answer?
Well, she was as exasperated as I was. She knew full
well how efficient companies would not even need to ask
about that sort of thing, just be there. So I was
pushing on an open door, as far as that was concerned.
Can you help us a bit more with what she explained to
you?
Yes. I mean, I said, literally, "Susan, okay, where's
the general file on this that will help to give lan and
myself an efficient briefing on what has been going
on?", and she said, "There isn't one". I mean, I think
I probably used an expletive. And she was, you know,
I can't fault Susan. She just knew there wasn't
anything there.
Can we look, please, at POL00344051.
Ah.
You recognise this document?
Oh, yes.
Is this a document that you drafted or Mr Henderson?
\ did.
What was its purpose?
Well, Susan had said to me, as best I recall, and
I recall things pretty well, she said something along
the lines of "I've been asked to take over the POID --
146
relating to the 29 MP-referred cases, and the 20 cases
referred by the JFSA, Second Sight has gained an insight
into the workings of [the Post Office's] Investigation
Team."
That might help you to date it ~
Yeah, on reflection, this was a little later than end of
2012. This was sometime early in 2013.
Thank you.
"The following observations are based solely on what
we have seen in those case files. We have not
interviewed any of the members of the Investigation
Team, nor its senior management. We have not reviewed
its mandate, manpower or workload. We have also not
researched the legal basis on which [Post Office]
conducts either investigations or prosecutions. With
that proviso, we make the following interim
observations:
"1. [Post Office] Investigators and investigations
are overwhelmingly focused on obtaining an admission of
False Accounting from the interviewed [subpostmaster]."
Did you form that view based on reading the file and
in particular the interviews?
Yes.
"2. [Post Office] Investigators often appear to have
paid scant attention to the interviewee's assertions of
148
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innocence or his/her reference to specific transaction
anomalies. They seem to have shown little or no
willingness to establish the underlying root cause of
any given shortfall.
"This disinterest seems to be driven by the desire
to ‘get the money back’ from the [subpostmaster],
knowing that a False Accounting conviction will provide
a relatively inexpensive pathway to that goal. In the
event that [a subpostmaster] has not committed any
criminal offence, then clause 12 of the standard
contract provides an equivalent pathway to asset recover
using civil law.
"In either event ... since [Post Office] doesn't
need to show where the money has gone, investigators see
no business benefit in trying to establish the
underlying root cause(s) of the loss.
“Under the contract ... the burden of proof (that
they are not responsible for the loss) falls on the
shoulders of each [subpostmaster] even though none of
them (in the cases reviewed) had any investigative
skills and their requests for assistance and provision
of underlying data were routinely denied, mostly on cost
grounds. This meant that the accused had neither the
expertise, the external support, nor the data to
establish the true reason for the loss and thereby
149
truth' (See comments on the consequences of ‘Tunnel
Vision’ at the foot of this report)."
I am not going to read the rest of the report. It
will be there for anyone else to read. You then go on
to make some recommendations and why those five problems
that you have identified are indeed problems.
Yes.
This report is headed up as "Draft"; was it ever
finalised?
No, I'm afraid not. I think that -- it served its
purpose. Susan, I think, was foisted off -- I think she
had to take over the department in the end, and so --
and it was just done as a kind of an aside. So I'm
afraid I never did see the need to finalise it. But
I stand by everything in it.
Can we look at what some other documents tell us as to
what happened with the report. POL00245685. This is
an email of much later from Amanda Peacock (sic) of the
CCRC --
Pearce.
-- to Rodric Williams, you're not copied in. She says:
"I've managed to find a bit more information about
the report which Ron ... apparently wrote.”
That's the document we've just looked at.
“Ron tells me that", and then there is a quote
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either prove their own innocence or realise that they
really were responsible for the loss."
Was that on a reading of the 49 case files?
Yes.
Your third provisional view or conclusion was:
"In none of the cases examined so far did any
Investigator record anything that indicated that there
might be any widespread systemic problem worthy of
investigation, despite similar allegations being made by
different, unconnected, postmasters [subpostmasters]."
Then if we go on to 4:
"We saw a repeated failure to reach consensus or
closure with the interviewees. Where the
[subpostmaster] was wrong in his or her assertions, one
would expect that to be convincingly articulated and
proved by the Investigator. Time and again, however,
the Investigator and the [subpostmaster] got close to
consensus but failed to arrive at it.”
Then 5:
"The overwhelming impression gained from reviewing
the transcripts of investigative interviews is that the
[subpostmaster] was viewed as an enemy of the business.
The culture within the Investigation Team appears to be
‘one of a ‘presumption of guilt’ when conducting
an investigation, rather than the aim of ‘seeking the
150
attributed to you.
Did you engage in email correspondence with the CCRC
or is that a quote from you saying something over the
phone?
I suspect this is a quote from the meeting that I had in
Birmingham with the CCRC, at their request.
I'see. So you are said to have said:
“I wrote the report on The Investigations Function
in 2013 at the specific verbal request of ... Susan
Crichton ..."
Yes.
That's accurate, yes?
Yes.
"... who later shared with me her concerns about [the
Post Office's] Investigations Department (‘POID’).”
Yes.
\s that accurate?
Yes, when I said "shared her concerns", she said,
"I think you've nailed it", or words to that effect.
"Later, in the latter part of January 2014 as I recall,
my colleague lan Henderson sent a copy of the report
(still marked as 'Draft' as far as I recall) to Chris
Aujard, who at that time was Post Office's General
Counsel, copying Belinda Crowe at [Post Office]."
Is that accurate --
152
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Yes.
-- ie both that you said that and that the facts
themselves are true?
Yes.
"[Mr] Aujard had asked to see a copy of the report after
its existence was mentioned at a meeting of the
Mediation Working Group. [Post Office] ought to be able
to locate a copy of that email -- to which the report
was attached. As mentioned, it was sent by lan to those
two [Post Office] employees, copying also myself."
Is that accurate that that's what you said but also
the underlying facts, that Mr Aujard had asked to see
a copy of the report and it was sent over to him?
Yeah, I think it was lan, Mr Henderson, that relayed to
me that Mr Aujard had asked him in. So I don't think
Mr Aujard asked me. I think he asked lan. But I'm
a little bit hazy on that. But I know the request came
from Mr Aujard and that's why an old copy of the thing
was dusted off and produced.
Okay. He accepted when he gave evidence that he
received the report from Second Sight?
Yes.
Do you know why it was being sent to him?
Well, as it says here, it had been mentioned and --
I recall it being mentioned in the Working Group
153
SIR WYN WILLIAMS: Yes, I can.
MR BEER: Thank you.
Good afternoon, Mr Warmington. Can we turn up,
please, page 21 of your witness statement.
Yeah.
Paragraph 46, which is in the bottom half of the page.
You say:
“After discussions with lan Henderson as to the
seriousness of his findings of probable prosecutorial
misconduct from his review of the small number of legal
files to which he had been given unrestricted access
(only seven as [you] recall it), [you] decided to speak
directly with Susan Crichton about that very important
matter. I believe this discussion took place in August
or September 2012. During a meeting with her I said
that, whereas I was confident that Second Sight had the
ability to assess the adequacy of evidence in cases of
suspected fraud and financial theft, we were forensic
accountants, not lawyers experienced in criminal
prosecutions or defence, so it was essential that our
findings be quickly, thoroughly and independently either
ratified or refuted by a competent barrister experienced
in criminal cases. Susan who, like practically every
other General Counsel that I had ever met, claimed no
expertise herself in matters of criminal prosecution,
155
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meeting, and us being -- lan and I being surprised that,
yet again, a key document had not been handed over from
one General Counsel to the next and, therefore, it was
obviously something that, although I'd produced it for
Susan, I'd produced it for her in her capacity as
a General Counsel and, therefore, he was entitled to see
it.
Was anything done about what you found in your five
points or your recommendations second time around,
ie when it was produced to Mr Aujard?
Not to my knowledge.
MR BEER: Thank you.
Sir, it’s just gone 2.05 (sic). I wonder whether we
might take the afternoon break now until say 2.20
(sic) -- 3, rather, 3.20.
SIR WYN WILLIAMS: Yes, I was beginning to wonder if there
was something wrong with my clock!
MR BEER: Time slows down when you're standing here, sir!
SIR WYN WILLIAMS: In any event, we will take the break for
the period you mentioned.
MRBEER: 3.20, sir.
(3.08 pm)
(A short break)
(3.21 pm)
MR BEER: Good afternoon, sir, can you see and hear us?
prop,
154
said that she would take the matter to Cartwright King."
So, firstly, this was a face-to-face meeting, was
it?
Yes.
Was it just you and Susan Crichton present?
Yes.
You drew to her attention matters of prosecutorial
misconduct that your colleague, Mr Henderson, had
uncovered in a small number of files to which he had had
access?
Yes.
Can you recall, in general terms, what the type or
species of that prosecutorial misconduct was?
Yes. In every case, inattention to the underlying root
causes of the shortfalls that were being pursued civilly
or criminally but, also, as lan has mentioned, the
failure to disclose, as far as he could detect --
because I was relying on his input on this and it was
entirely credible to me -- not disclosing exculpatory
evidence, evidence of innocence, if you like, or
evidence that would undermine the prosecution or civil
case.
So this -- I had, and still have, less experience
than does lan on matters of prosecutorial conduct but it
was pretty compelling to me and so I thought that
156
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I needed to share those views with Susan.
Did any of the five things that you were subsequently to
mention in the first part of 2013, in that draft
document that we looked at before the break, form part
of your briefing to Susan Crichton?
Yes, and I think all of them but, as is my nature,
I probably put it in rather coarse language.
What did you envisage needed to happen as a result of
the provision of this information?
Oh, it was very clear. I said, "Don't rely on us, you
need to deal with this urgently and go and either
rubbish what we've said, or confirm it, and if, God
forbid, an expert in criminal law says that Mr Henderson
and I -- more Mr Henderson -- is right, you're going to
have to review a whole load more cases, not just the
ones that we've looked at. But, if it turns out that
we're wrong, have the decency to come back to us and
tell us 'you're talking nonsense’ and we will
recalibrate". And that's about the sum of it.
Now, none of is ultimately finds its way into the
Interim Report of July 2013?
No.
Is that because you saw this as going down a different
route or I should ask the broader open question: why?
Ooh, I think it's what we were referring to earlier,
157
Then you tell us over the page that you:
".., laughed out loud at that ... simply
preposterous suggestion and responded by saying that
Cartwright King would [be] entirely unsuitable ...
because they could not ever be viewed as independent and
they would ... then be 'marking their own homework'."
Yes.
You suggested going to a higher ranking firm and
suggested some names. You were astonished at her reply,
which was along the lines of:
".., 'that won't work, the Board won't approve that
sort of expense’. I responded with words along the
lines of ‘Well then, you're all", and then there's
an expletive, I suspect.
I'm afraid so.
Which has been caught by --
Sadly.
-- our data protection machine:
this is an extraordinarily important issue, why
is cost in any way relevant?"
This was a very serious issue, wasn't it?
Oh, yes, at that point it was the most serious issue
that we'd come across and it kind of remained so for
years afterwards.
Because the MPs had said that they were interested on
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Mr Beer: this Interim Report was produced in order to
just come out with something that evidenced the work
that was going on, and had gone on, and it wasn't
intended to cover all of the issues that were still
open. My view on this was: Toddle off, get the
independent view and have the decency to share it with
us.
So, yes, with the benefit of hindsight, some of
these embryonic or as yet unconcluded thoughts could
have been dumped out in the Interim Report but we
didn't.
Because you've explained to us already that the primary
concern of the MPs on behalf of their constituents was
possible prosecutorial misconduct and here you were
potentially uncovering some?
Yes, but, to be fair to Post Office and to Mr Henderson,
I had to consider the possibility that we were wrong.
I didn't think we were, I don't think that lan was, and
lan never has been, but we had to give the benefit of
the doubt and say, "Go off and get a second opinion on
this", but not the second opinion that they eventually
sought.
Moving to that, you say at the foot of that paragraph,
she said, Susan Crichton, she would take the matter to
Cartwright King.
158
behalf of their constituents in the cases that had gone
to prosecution?
Well, let's face it, the -- Lord Arbuthnot was -- he
had, I think, three constituents, one of which was Jo,
and this was central to the reason he was pushing for
the investigation to be carried out. So it was central
in his mind and, if it was central in his mind, you can
bet that it was central in the minds of his group of
MPs.
Did you find out what, in fact, happened at this time,
or shortly thereafter, namely in August or September
2012, whether or not your suggestion of referring this
to a competent barrister experienced in criminal cases
or, as Susan Crichton said she was going to do, refer it
to Cartwright King, in fact happened?
No, we didn't find out until much later what actually
happened.
Is it your understanding that what actually happened was
a result of your suggestion in August or September 2012,
or was prompted by something entirely different, namely
the Simon Clarke Advice of July 2013?
Simply to say, I don't know. My ego would like to think
that we precipitated the action that was taken but
I doubt it. Whether the Clarke Advice was sought
because of what we'd raised or just because they thought
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it was a good idea anyway, I don't know.
Okay, that wasn't fed back, that wasn't a communication
that you were a party to, ie the motivating cause for
going off to Cartwright King?
No, I regret not sort of chasing the point more
vigorously. I mean, I probably should have gone back
and said, "Where the devil have you got to on this
point?” But I think that coincided with -- I can't for
the moment remember why -- I'm afraid, why I didn't go
back and kick Susan's door down on this. I'm not
sure -- she left at some point, so I think
September 2013, I think.
Yes, so quite a bit later than this, yeah.
Can we look at an exchange that I showed Mr Henderson
this morning of May 2013 between you and Simon Baker.
Mm-hm.
POL00144687, and look at page 2, please, and scroll
down. There's an email to you from Simon Baker of May
2013, so a couple of months before publication of the
Interim Report.
Yeah.
It looks like it's in readiness for a meeting that
you're to have with Paula Vennells. He, Mr Baker, says:
"Just to ensure we are on the same page, Paula would
like to say we have agreed the following with Second
161
qualified to answer a legal question about what may or
may not be an unsafe conviction or suspension."
Just three points on that, firstly. You had, in the
earlier August or September, been told quite a lot by
Mr Henderson about prosecutorial misconduct and you had
yourself told Susan Crichton about prosecutorial
conduct. We don't see that reflected here.
Mm.
"This was going to be dealt with by a different route,
this was going to be at my suggestion taken up by
an experienced criminal law barrister to see whether
we're right or wrong"?
Mm-hm.
Instead, you essentially bat it back and say, "This
isn't within our sphere of expertise"; why is that?
You know, when I looked at this earlier today,
I couldn't quite work out why I worded it this way. I'm
sort of hovering around the thought that I was actually
being facetious. I was being -- I was -- I was so
irritated by the daft question that I've answered it in
a rather daft way. What I meant was, I think by that
point, we had made it abundantly clear -- I say "we" --
lan and I had made it clear -- that we weren't going to
use the term "systemic defects". It follows that, if we
weren't going to define -- say there had been any
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Sight, can you confirm you agree ...”
Then 2:
"By using the 2-3 cases you will answer the
question: have systemic defects in the Horizon system
resulted in the wrongful conviction or suspension of
subpostmasters?"
Now, can you see that that question is mixing two
things: defects in the Horizon system, which are
systemic; and the conviction, wrongfully, of
subpostmasters?
It may well be combining two things but I think it’s
very carefully crafted to be -- ask us to agree to
something that is ludicrous.
Then at 4:
if question 2 was posting to you today, you
would answer it 'no’.’
Then can we see your reply on page 1. You say at
the top of the page:
"I'm surprised at the questions you have raised as
these include matters that are outside our scope of
work."
Then scroll down to 2, you reprint his question and
say:
"Our role is to establish the facts relating to
specific MP or JFSA nominated cases. We are not
162
systemic defects, how on earth could there be systemic
defects that had resulted in a wrongful conviction or
suspension of the tiny volume of subpostmasters whose
cases we'd looked at, at that point? It was just
patently absurd, the -- and I probably should have said
that and not answered it as narrowly as I did.
I wish now I'd actually sort of given them both
barrels in terms of the suspicion that there was
wrongful prosecutions but I don't -- I can't recall
exactly why I worded it that way, I'm afraid, Mr Beer.
Okay. le "Hold on, we told your General Counsel about
this back in August or September 2012, we found, on
a preliminary basis, some probable prosecutorial
misconduct. We explained then that we didn't have the
experience and we suggested a way forward for the Post
Office. It hasn't taken that up"?
Yes, that's in abeyance: where's the blasted answer to
that? But, certainly in terms of this narrow question,
of course, we'd be stark raving mad if we had agreed to
that. You know, it just wouldn't be a reliable
statement if we had made it.
Again, I think you may have answered this already: do
you think, on reflection, this episode, ie picking up
probable misconduct of prosecutions as early as August
and September 2012, raising that with the Post Office
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suggested in a solution, them not taking it up,
seemingly, but then asking you to use a two or
three-case sample size to (a) answer the question
whether there are systemic defects and (b) to say that
has not resulted in the wrongful conviction of any
subpostmasters is absurd, should have been included in
the Interim Report?
Yes, we were somewhat inured to receiving absurd
responses from Post Office already at that point. It
would have been nice if we had been less constrained and
less professional in expanding on that, perhaps, in the
Interim Report. You know, we didn't, and I suppose --
I'm not inventing this but I think that, at that point,
I still was naive enough to be thinking that my
suggestion to Susan was underway and that there would be
an educational input to us, which would have said, "Hang
‘on, boys, thank you for alerting us to this but you're
completely wrong on that. Here is the words of, you
know, a Mr Atkinson or whoever", somebody of that
stature, that would have said "You're barking up the
wrong tree, you two", and I was ready to receive that
input but it never came.
Thank you. That can come down.
You tell us in your witness statement that you need
to correct something that you heard in Ms Crichton's
165
The first point is that you say "we did not think
(from what we had seen) that [Mr Jenkins] could have
been aware of the duties that an expert ... would owe to
the court"; is that a view that you formed
contemporaneously, ie back in 2012/2013?
I find it difficult to think that we could have been as
crisp or --
Prescient?
Yes, prescient as it turned out to be. But having said
that, lan is and has served as an expert witness —-
I have never chosen to do that work -- and I know, in
that sense, what an expert witness looks like and how
they conduct themselves, and the form and format of
expert witness reports, I've seen enough of them. And
I didn't think -- I recognised as early as that, without
the benefit of second sight -- haha -- that we would
later learn what we have later learned in regard to his
briefing and the modifications of his witness
statements, and so on.
He was just an expert in the Horizon system and lan
and I knew enough about it to say, "Well, how on earth
could the courts accept that this was -- this person who
had, if you like, never" -- we didn't know at the time
he'd never before acted as a expert witness but he just,
he didn't come across as an expert witness. He came
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evidence and the thing that --
Yes.
-- you need to correct is she said that you were
impressed by Mr Jenkins as an expert witness. You say
that, to the best of your knowledge, neither you nor
Mr Henderson said that you were impressed by Mr Jenkins
as an expert witness but, instead, impressed by him as
a computer or systems expert; is that right?
Yes, exactly.
Was it you or Mr Henderson that said that to Susan
Crichton?
Probably both but it would have come more credibly from
Mr Henderson, who had more contact with Gareth Jenkins
than I did.
In your witness statement, we ought to turn it up, at
page 49, paragraph 106 -- page 49 at the top, second
line in, you say:
"What we did say, as I remember it, is that we were
impressed by him as a systems/computer ‘expert’. The
distinction was clear to us, we did not think (from what
we had seen) that he could have been aware of the duties
that an expert witness would owe to the court and so was
partisan in his views concerning Horizon. It is
possible that we failed to make that distinction clear
to Susan, such that she misunderstood on that point."
166
across as an expert. So I don't think we -- we weren't
prescient but I know that we would not have described
him as -- to Susan, as "a very good expert witness".
That would have been silly of us to do that. We didn't
do something like that.
Were you made aware of the existence of the Simon Clarke
Advice of 15 July 2013 in either 2013, '14 or '15?
No.
Therefore, you weren't shown a copy of it at that time?
That's correct.
When did you first become aware of the existence of the
document?
Well, actually, it was -- it came out with a fanfare of
trumpets, didn't it, at the Court of Appeal, when the
Clarke Advice was first -- in the Hamilton --
Okay, so in November 2020?
Yes. I had not seen it, neither, as far as I'm aware,
had Mr Henderson, seen it before that date.
Had you been made aware by the Post Office of the
substance of the conclusions reached in relation to
Mr Jenkins?
No.
There's evidence that the Inquiry has that, in autumn
2013, specifically September, the Post Office lawyers
knew that there was at least a serious issue as to
168
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whether it, the Post Office, had properly instructed
Mr Jenkins as to his expert duties. Did anyone within
the Post Office ever reveal that to you?
No.
Did you know that Mr Jenkins had given evidence, on one
view, as an expert in court proceedings?
Yes, I think the first I knew of that, to be precise,
would have been when I looked at the Seema Misra, Lee
Castleton and other cases, where he'd submitted written
witness statements, and I think only in one case did he
give -- did he follow that up with oral evidence.
Had the Post Office confirmed to you that it had relied
‘on Mr Jenkins as an expert witness in a series of
criminal cases -- I think 15 in total -- but that it had
not instructed him as an expert witness properly or had
failed to explain the duties owed by an expert? Would
that have added to your concerns about the conduct of
criminal prosecutions by Post Office?
Well, the first part of the question is no they didn't
tell us. And would it have added? It most certainly
would have.
But would it have made you question still further the
competency and ethics of the Post Office prosecutors?
Yes.
If you had had revealed to you the substance of the
169
Thank you.
Can I turn to your concluding thoughts, which you
set out from paragraph 107 onwards in your witness
statement. In answering our question, "Would you have
done anything differently", you say this: firstly, you
wish you'd refused to allow your firm to be contracted
with the subject of the investigation. That's a very
big hindsight point, isn't it?
Yes.
But more particularly, you say:
"I wish I had demanded, rather than asked, to more
frequently see Paula Vennells, but also, when I was
doubting whether the truth was penetrating through to
her and the Board, I should have demanded to address
[the Post Office's] full Board ..."
Did you ever receive an invitation to address the
Board?
No, other than as has been mentioned earlier today, the
post-firing December 2015 invitation to speak to
Mr Parker.
Did you ever ask to see the Board?
No, I'm afraid not. I think it's fair to say I didn't
and I wish I had.
You say in (c) that you wish you had flatly refused to
communicate with the Post Office's CEO and its Board
171
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Simon Clarke Advice of 15 July 2013, what effect would
that have had upon you as to the propriety of certain
criminal proceedings conducted by the Post Office?
Well, it would have heightened our suspicions that it
had been a complete and utter mess.
You said that one of the cases you were considering was
Seema Misra.
Yes.
Did you read a Seema Misra file?
I think lan had looked at the file. We had the scanned,
searchable images of those files on what we call CD1,
and I reviewed those. So I came to that stuff after lan
had already looked at the paper documents.
To the best of your memory, the Seema Misra file, was
that the disclosed documents, ie the documents that
would have been disclosed to the defence or was it the
prosecution case file?
I'm not sure I know the answer to that. It comprised
a lot of documents. I did not, I think, establish which
among those documents had been disclosed to the defence
and which hadn't. That would be more the sort of work
that lan was doing. I was -- I looked at every document
that was produced to us and so I had reviewed those
documents electronically, and -- but to me, at that
point, it was just another case.
170
through the conduit of Chris Aujard, Belinda Crowe,
Patrick Bourke and Angela van den Bogerd. Were they the
four principal actors who performed the function of
conduit?
Yes, there might have been others. I think Rodric
Williams was in that sort of central team but those are
the main ones -- and, of course, later, after Chris
Aujard left, Jane MacLeod, the absent witness.
Why do you, on reflection, wish that you hadn't used
them as conduits?
Well, as is immediately obvious to anybody reviewing the
transcripts or, better still, listening to any of the
tapes, it was awful, just dealing with people who were
not just seemingly failing to understand just about
everything we said, but were, we now know -- but it was
apparent at the time, we suspected at the time -- were
in a sort of cabal that was colluding to or conspiring
to thwart every move that we made, and to -- forgive the
language or not, as you see fit, Mr Beer -- but I felt
that I was -- if you like, I accepted that I should be
talking to the monkeys instead of the organ grinder.
And I felt -- I now -- with retrospective, with
hindsight, I feel ashamed that I allowed myself to fall
into that trap.
You tell us in paragraph 108, in answer to the question
172
(43) Pages 169 - 172
The Post Office Horizon IT Inquiry
"Any other matters that you wish to bring to Sir Wyn's
attention?”, if you had to select one document, it would
be an email that you sent on 3 March 2015, which, in
fact, I looked at with Mr Henderson this morning.
Can we look, please, rather than repeat that
exercise, we've got that on the transcript, look at
SSL0000109. Thank you. This is in relation to the case
of case M018, Alun Jones. Was he a subpostmaster?
9 A. Yes.
10 Q. Idon't think we've got a date on this one, but is this
ONOaARWN
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12 A. Yes.
13 Q. Canwe go to page 8, please. You say to him in the
14 third paragraph:
15 "... [know. It's absolutely -- well, I tell you
16 what. I've been an investigator for -- off and on for
17 about 40 years. I've done other jobs at some point but,
18 you know, I've been Global Head of Fraud Investigation
19 for two of the world's largest companies, and so I've
20 investigated frauds in 110 countries around the world,
21 thousands of fraud cases."
22 Skipping a paragraph:
23 "I have never come across anything as bad as this.
24 This is the worst corporate behaviour I've ever come
25 across."
173
1 will be able to find that, but I suspect it was -- I'm
2 kind of making an educated guess here, I'd say sort of
3 August 2014.
4 SIRWYN WILLIAMS: That's fine. It was in the context,
5 then, was it, of you gathering information in terms of
6 your role in the Mediation Scheme?
7A. Yes, mean, I mentioned in my witness statement, sir,
8 that there was, in a sense, two sorts of recordings:
9 there were the recordings that any investigator would
10 routinely make when dealing with a -- when interviewing
11 a subject. I wouldn't call them a suspect, a subject,
12 ie one of the subpostmasters. I would routinely record
13 those, seeking their permission to do so, with a view to
14 later going back and checking what they'd -- exactly
15 what they'd said because it wouldn't always mean
16 immediately what I would later learn that it did mean.
17 It was one of those conversations, that one. It
18 wasn't one of the sort of covertly recorded calls that
19 I felt pressed to make later on in the - when dealing
20 with Post Office Management.
21 SIRWYN WILLIAMS: All right, thank you. I may have another
22 question but I'll wait to see if any of the counsel on
23 behalf of the CPs ask it.
24 THE WITNESS: Thank you, sir.
25 MRBEER: Sir, just on the issue of dates, where we can see
175
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He says:
"But they're bullies ..."
You say: "Yes."
Then the conversation continues.
Is what you said to Mr Jones there an accurate view
of your engagement with the Post Office or does it
contain hyperbole because you were speaking to
a subpostmaster?
A. That's a very good way of expressing the question
because one does encourage and develop rapport with
whoever one is speaking to, it doesn't mean you become
chameleon like. But, no, it's exactly what I felt then
and I still feel it now.
MR BEER: Mr Warmington, they are the questions I ask you.
I know that there are some questions on behalf of one
subpostmaster group -- in fact, two subpostmaster
groups, I think it's --
SIR WYN WILLIAMS: Before the questions are asked, the date
of that conversation with Mr Jones, can you give me any
idea of the year we are talking about?
A. I'm not sure, sir, I suspect it was 2014, probably
towards the end of 2014, because my view was quite
negative at that point, it became more negative as time
went by. It wouldn't have been 2015. I would guess --
and the recording will have a date on it, so the Inquiry
174
a date, either because of the recording description
that's given as RJW261015, we've put that on there.
Where we can't see a date, the transcribers have not put
a date on there.
SIR WYN WILLIAMS: = Right. Anyway, I simply wanted to be
clear in my mind that it was a conversation while
Mr Warmington was still investigating, so to speak.
A. Yes, it was. Yeah.
MR BEER: Thank you, sir. I think Mr Stein.
SIR WYN WILLIAMS: Yes.
Questioned by MR STEIN
MR STEIN: Mr Warmington, a few areas to just deal with
briefly, or three, I think, to deal with briefly and one
slightly more lengthy about suspense accounts, okay?
A. Mm-hm.
Q. Allright. You've answered some questions from Mr Beer
regarding the possibility of the Post Office keeping
a general file.
A. Mm.
Q. Did you find out from Ms Crichton whether there was
anything similar to a general file that might have been
kept by Fujitsu?
A. Ooh, no, and I didn't -- I don't remember asking that.
It would have been a good question to ask but I don't
remember doing that.
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Moving, then, on to just a couple of other small areas.
There was an NDA, non-disclosure agreement, that was
signed by Second Sight.
Yeah.
We've heard today the evidence of Mr Henderson about how
he viewed the fact that he wished that there'd been
an agreement -- essentially a whistleblowing agreement
part of the contract?
Mm.
I note that you refer in your first statement at
paragraph 102 to the fact that both you and
Mr Henderson, you offered your assistance to Freeths to
provide assistance and support for subpostmasters,
presumably in the GLO process; is that right?
Yes, that's correct, yeah.
But the severe restraints of your contract and its
confidentiality undertakings ensured that did not
happen?
Yes, with the exception of two meetings. One with
Patrick Green, very briefly, when we were essentially
told "There's not much you can tell us", or, you know,
"I don't want you to tell, thank you very much, we'll
find out things ourselves", and, more importantly,
I think, in a much longer meeting with Jason Coyne and
Dr Worden, when we were helping them to arrive at their
177
‘on us -- I'd go so -- without bragging, I'd go so far as
to say very, very few other firms would have withstood
that.
If it hadn't been for the courage of Mr Henderson
and maybe my, you know, not telling my wife what all the
risks were, I would have pulled stumps on the whole
thing.
Talking of courage and dedication, Ms Linnell, Kay
Linnell, is someone who has provided, over now many,
many years, superb support to Sir Alan; do you agree?
I hold Kay in the very highest regard. She flew at me
like a tigress in the original meeting, which wasn't
amusing until about ten minutes later. I mean, she
obviously suspected that we were incompetent or those
that were going to be -- produced a whitewash, or both.
But, as the case evolved, for very little recompense --
and I know what she was paid -- she was required to keep
an eye on us to make sure that we weren't producing
a whitewash and that we were conducting ourselves
properly, and she did a super job.
Over the many years, she has also provided, with
a business partner, Mrs Jeremiah, hours and hours, days,
weeks, months of support annually to subpostmasters with
their business affairs so badly affected by the Post
Office; do you agree?
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witness statement. I think they produced a combined
witness statement in the end.
If you hadn't had the restriction of the NDA, do you
feel that would have enabled you and Mr Henderson to
come forward with more information at perhaps an earlier
stage?
Oh, yes.
Learning lessons for the future, in relation to anyone
else that engages in work with a corporation such as
POL, or any other company, do you think there should be
a different way of handling those questions, an NDA that
allows for an exception in relation to whistleblowing?
How would you regard that process for learning lessons?
Thank you, Mr Stein. I think it stems -- one goes back
to the underlying problem. To try and patch the
situation by having an escape clause in the NDA
circumvents the -- or ignores the original problem,
which we've referred to. If you make the investigator
a vassal of the subject of the investigation, nobody
should be surprised that there's tears before bedtime.
You know, this was a daft way of carrying on
an investigation and I only hope that one of the
recommendations from this Inquiry is that that is not
a particularly clever way to go about conducting
an independent investigation because the pressure it put
178
I not only agree but I think she's one of the few people
that hasn't been sitting in the dining car of the
Horizon gravy train. I mean, she has contributed to my
knowledge massively to this case without being paid.
Thank you.
Now, let's turn to suspense accounts.
Yeah.
Allright. Your statement, second statement,
WITNO01050200, we can go to that, please, and go to the
subheading, paragraph 3, "Suspense Accounts". I wonder
whether that paragraph can go up on the screen, please,
WITN01050200, paragraph 3, which is at page 2.
Grateful.
Now, here you've made the point that you've:
"... heard the Inquiry many times seeking
clarification in respect of concerns that were first
expressed by Second Sight [and] repeated by others."
Mm.
So, obviously, we know this was dealt with in relation
to the Working Group, Sir Anthony Hooper was raising
this. This was a matter of clear discussion; is that
correct?
Yes.
Now, at paragraph 5 you set out there -- and I'm just
going to ask you to explain, please, what you're saying
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here -- paragraph 5, you describe the different types of
suspense accounts. The first one was affected by,
essentially, the closure off of the original suspense
accounts by the IMPACT Programme, that the Inquiry heard
from, I think, if I remember right, from Ms Harding, who
described her work in relation to that. So the first
type of suspense accounts, what were they?
Well, they were simply accounts within Horizon itself at
branch level which allowed shortfalls, or also,
theoretically, surpluses, to be parked while the
subpostmaster and his or her staff was investigating it
to find the root cause. They -- because the balances
that had been posted by the subpostmasters, those
accounts started to clock up quite seriously, and cause
concern in Post Office itself. The fantastic solution
that was evolved to do that was just to remove the
functionality, and it was replaced with the settle
centrally and dispute function, which was meant to be
a sort of an adequate replacement but it wasn't.
You conclude in the final part of paragraph 5, in
relation to subpostmasters, the removal of the suspense
account at that time, leaving many of them with no
realistic alternative, which when faced with shortfalls,
that they could neither understand nor make good, but to
falsify branch books, in order to buy time.
181
there was -- the onus was on the subpostmaster to carry
the burden of proof and work things out. There was
always this point that "Don't worry, it'll sort itself
out; an incoming TC, a credit TC, in that case, will
sort out your problem", but never the promise as to how
long it would take for that to zero out the amount that
was in suspense account.
I think you recognise -- well, I'll ask it as
a question: do you recognise that there was a very real
issue for subpostmasters trying to, in fact, find what's
gone wrong, see if they can look at the material that
they had, with huge limitations of access into the
Horizon system?
Well, that was the very point of course that Sir Alan
himself raised first. There was a person that
understood the Point of Sale systems and there he found
himself looking at this 8 centimetre wide piece of paper
that was across the room to try to find the reason for
a shortfall, simply not remotely feasible if you're
looking at -- at a whole month's transactions to try and
find out why you've got a shortfall of, you know,
£19,000, or whatever.
It was just not -- to say it wasn't user-friendly is
a raging understatement. It just wasn't a reasonable
expectation to expect the subpostmasters and mistresses
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Yes.
Is that how you see it?
One of the -- I mean, I mentioned one of the incomplete
replacement -- functional replacement, one of the
restrictions of the settle centrally and dispute
function was that there was a value limit on how much
could be placed there. I think it was essentially based
‘on the subpostmaster's salary. So if you had
a subpostmaster on £18,000 a year and you tried to post
a shortfall of £19,000 a year, it wasn't going to work.
If it was 10,000, it wouldn't work, he couldn't do it.
If it was 5,000, he couldn't do it.
There was a limit to how much could be put in there
and that meant that all the big shortfalls that we were
seeing just couldn't be parked anywhere. They had to be
dealt with immediately on the final -- on the day that
that shortfall manifested itself in the books.
Do you recall that, during the IMPACT Programme, the
double-whammy effect was the removal of the suspense
accounts and also the pressure, essentially, recognised
within the IMPACT Programme, on the subpostmasters? In
other words, they threw back upon subpostmasters the
need to prove that it wasn't their fault?
Yes, I think there was always an expectation that, even
something in the original pre-2006 suspense accounts,
182
to be able to find the underlying root cause of
a problem using the material that they had in the
branch.
Moving on, then, from the time of the pre-IMPACT project
suspense accounts, help us understand a little better
the suspense accounts that continued to exist after that
time?
Ah, right. Well, now we're talking of course -- I mean,
there's a lot been said about this, a whole -- I'll be
very brief, unless you want me to be otherwise -- and
that is that when I first -- in fact, it was Sir Anthony
Hooper that said -- asked the question, under the
umbrella heading of "Where the devil did the money go"
he said, "Is it possible that a shortfall in one branch
could be accounted for by a surplus in another?", you
know, what's happening here? And "Second Sight, find
out", and so I said something like "there'll be amounts
in suspense accounts", and the reach that I got was
"What are you talking about? Don't know what you're
talking about, we don't have any suspense accounts".
"Yes, you will, you'll have suspense accounts".
So we started to pursue that and, again, it was like
swimming up a waterfall, in terms of explaining what we
were talking about and why we were interested in that
and, eventually, we explained that you -- wherever there
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is a difference between what one of your clients, like
Royal Mail, or National Savings and Investments, or
Camelot, or whatever, says is due to or from them, if
that is different from what your own books in Post
Office shows is due from or to them, there will be
entries in both parties’ suspense accounts, and those
would expect -- as Mr Henderson has mentioned, ordinary
businesses would expect to clear those very quickly
indeed, otherwise they get out of hand.
What does "very quickly" mean?
Well, in Citibank, they had to be cleared by 7.30 the
following morning and you'd expect them to be, because,
if Citibank does a $500 million foreign exchange deal
with Bank of America and one processes it at 500 million
and the other at 50 million, you'd better get to the
bottom of that damn quick.
Does it make any difference that Post Office is dealing
with, say, 11,000 branches and the size of the system in
operation?
Oh, yes.
Does that have any relation to the getting it done PDQ?
Yes, I'd be a cruel person to fail to acknowledge that.
It was a complicated process.
Meaning what? Meaning that it should take longer than,
say, 24 hours? It should take any particular time?
185
Yes.
You are an accountant?
Yes.
Materiality seems, if we understand it correctly, to
vary, depending upon, perhaps, the size of the business,
so if we look at something the size of, say, Lloyds
Bank, I use as an example, what they relate to a banking
business in relation to materiality, in concerning its
turnover and operations, £10,000 may not be material; is
that a fair way to look at it?
Yes.
Regarding the question of materiality, where you've got
this complex mixture, so materiality to a subpostmaster
or mistress may be £5,000, £10,000 maybe a few hundred,
but to the overall Post Office business, it may be --
may not be the same. Is that a fair description of the
problem?
Yes, it is, the only thing I'd add to that, Mr Stein, is
if we're dealing with -- there was a sort of uniqueness
about the Post Office business model, where the coalface
workers, the agents, the subpostmasters, were separate
businesses and they were held accountable for the debts.
We know all that stuff, don't we? There's nothing new
in what I've just said. That's radically different
from, shall we say, a big bank. If a shortfall, whether
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What would be your estimate as to how --
If it was auditing it, Mr Stein, I would be fairly
forgiving if it was taking a month or maybe even two to
clear some of those items but I would understand the
impact of the time delay in clearing those on the people
impacted by it, whether it was a customer -- not so much
the clients, they can live with that sort of time delay,
but if it was a customer or a subpostmaster that was
having to wait two months, three months, six months, to
sort out a problem that he or she had had to cover
financially during that interim period, you can bet your
life we would have given a lot of credibility or a lot
‘of emphasis to that point.
So the driver from the auditor perspective would be to
get this sorted: it impacts real people, real families,
small businesses?
Yes, that's part and parcel of the reference earlier
that I made to materiality and, of course, Post Office
dined out on this sort of phraseology, that
contextually, the size and frequency of occurrence of
these tiny little amounts was so small and so
insignificant in their books as to be immaterial. But
to the people on the other end of the transaction you'd
bet it was material.
Materiality is a term of art used within accountancy.
186
ATM related or else, occurs in a bank branch of Lloyds
Bank and it's £12,000, it's immaterial, in their books
and it's actually immaterial in the branch's books
because nobody is being expected to pay it out of their
‘own pocket.
So the materiality issue is different in Post
Office's case because of the uniqueness of the business
model. I hope I haven't made that confusing.
Should that have been considered by the accountants as
being a different way to look at materiality within the
Post Office?
Well, it would have, if I'd been doing the audit, yeah.
Now, paragraph 11 of your second statement, you refer
then to the suspense accounts issue and the amounts that
remain sitting. If you can go to paragraph 11, top of
page 7, please -- thank you:
"It follows that any amount that remains sitting, as
a component of the balances in any of POL's client
suspense accounts, will always, in truth, properly be
owned by, and therefore be properly returnable to, one
of only four potential owners. Those four are:
"POL itself.
“One of POL's customers.
"One of POL's clients ...
"[Or a subpostmaster].’
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Then at paragraph 12, you then set out that you and
your colleagues:
"... formed a hypothesis that [you] wished to test
(and hopefully to disprove) that some of the
UNRECONCILED net credits that POL had every year (after
three years) credited to its own [profit and loss]
account might that have included amounts that, had POL
been able to establish to whom they truly belonged,
ought to have been returned to [subpostmasters/
mistresses and the branches]."
You go on to say this:
“We later learned from POL, when it wrote to us
about its Suspense Accounts, that it had released,
during the year 2010/2011, gross unresolved credits that
aggregated to £612,000."
Help us understand what that means and also help us
understand whether you had any other amounts for other
years going on through?
A. Yes, and I hope I haven't been too journalistic in
picking the largest amount that we told about because
they varied from 100,000, 212, and so on, and the last
figures that we had related to 2010/2011 and I believe
later there was perhaps a KPMG report that looked into
later years, and the figures went up even further. What
we were interested in was specifically point 4 there.
189
these issues in relation to the suspense accounts, what
has happened to the money, being paid into balance
shortfalls that may have been due to a Horizon system
error, where has it gone? Have you got an answer to
that question?
A. Simple answer is no. The slightly longer answer is
I have read, in material that has been supplied to me by
the Inquiry, reports by KPMG and others that took place
as late as 2020, that seemingly give some reassurance
that everything currently is okay.
What they didn't do was go back and pick up the
specific items that we drew to Post Office's attention
that had come to the surface out of the 136 cases that
we looked at, where specific examples of subpostmasters
not being reimbursed with amounts that they'd had to
cough out, in relation to one-sided entries, and so on,
the specific cases that we brought to the attention of
the Chief Financial Officer were not, as far as I can
see, ever even looked at by the subsequent auditors
that -- and accountants that allegedly gave a clean bill
of health on suspense accounts.
MR STEIN: Thank you, Mr Warmington.
THE WITNESS: Thank you, sir.
MS PAGE: Sir, thank you.
I should be able to finish by 4.30.
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We knew that it was likely that some customers had been
shortchanged. But, callously, we didn't give two hoots
about that. We weren't concerned about that.
Similarly, we weren't concerned if Royal Mail or Camelot
or National Savings and Investments had been
shortchanged in some way. Why should we worry? And we
weren't worried if Post Office had trousered, as it
were, amounts that it should have had trousered.
We were concerned solely with those items that
were -- that remained -- not uninvestigated. I suspect
they were investigated but unresolved, that were then --
that then found their way into the profit and loss
account.
It was deeply concerning that there existed the
possibility, I would go so far as, in my mind, to
a certainty, that some of that aggregate, 612,000, would
have been, had there been deeper and more thorough
investigation carried out, that would have included
amounts that would -- should rightly have been returned
to subpostmasters and there are enormous consequences
from that.
Q. Let me ask you the same last question I asked to
Mr Henderson: has the situation changed to date? In
other words, to the date of your evidence being given
now before this Inquiry, have you had a resolution to
190
SIR WYN WILLIAMS: = Okay.
Questioned by MS PAGE
MS PAGE: Mr Warmington, picking up on the last point you
have been asked about, I actually would like to take you
to that KPMG report, so we'll bring up POL00030909,
please. Is this the document that you were referring to
when you were answering Mr Stein's questions?
A. It certainly is.
Q. We can see there that that's from 2020 and I believe
we'll be able to hear who commissioned that. Have you
had a chance to look at it properly?
A. I've looked at it pretty thoroughly, yes.
Q. So if we go to the first page, there's a sort of set of
what we might call caveats?
A. Yeah.
Q. Is there anything that you'd like to draw the Inquiry's
attention to about those?
A. Ooh, wait a minute. Um, let me see. Ooh, hang on.
I mean, it's a pretty draconian sort of set of caveats.
Hang on a second. Well, obviously, the second
paragraph, I've gone through it all but coming back to
the second paragraph, the sort of the terms of reference
to me is always a sort of danger signal. What exactly
did they get asked to look at and did they -- were they
let off the leash to follow investigative instincts or
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The Post Office Horizon IT Inquiry
were they set on a set of tramlines and the clockwork
wound up to just go where the client wanted them to go?
Do you understand from that second paragraph, or indeed
from anywhere else, that they were let off the leash?
I got the sense that they weren't let off the leash
and -- because I mentioned in my second witness
statement that the obvious lines of inquiry that lan and
I would have pursued, along with our fellow
investigators, just didn't appear here. They didn't
even mention the sort of things, which was to look at
the history of what had been cleared and find out
where -- what Post Office had learned about who really
did have to be repaid when they actually bothered to or
actually found out who the true owners of items in
suspense were. Were any of the amounts that they did
bottom out returned to subpostmasters and, if it was
none, then we were wrong in our hypothesis. So I didn't
see any evidence —-
None of that is answered here, is it?
No, I don't think it is, no.
What we get in the third paragraph is:
"The report should not therefore be regarded as
suitable to be used or relied upon by any person or any
purpose including any court or other investigatory
proceedings.”
193
Post Office was absorbing sums into their profit and
loss, which rightfully should have been returned to
subpostmasters, who within Post Office would or should
have known that that was happening?
You want names? Well, it would have been the Chief
Financial Officer, Mr Cameron, who I think has been on
gardening leave, so he probably might not know that now,
and Mr Ismay, who was the functionary in Chesterfield,
whose department handled this stuff, and he was in the
meeting between myself, Mr Henderson and Mr Cameron,
just about two weeks before we were chopped.
Do you think that there's any directors on the Board,
apart from Mr Cameron, who would or should have known
about this?
Well, they all should have had known about it but there
wasn't a lot of attention to detail, as far as we could
detect.
Can I then also just ask you this about your
investigations: did you find that Horizon conducted true
double-entry bookkeeping?
Ooh, haha! I didn't ask you to raise that question but
I'm glad you did! I harbour a suspicion, and I've
mentioned it, I think, in my second witness statement,
that the assertion that Horizon is a double-entry
bookkeeping system is not safe. I think it is at
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Yes. Like us here!
Quite. Then we've got the paragraph on the right-hand
side, second down:
"KPMG does not provide any assurance on the
appropriateness or accuracy of sources of information
relied upon and KPMG does not accept any responsibility
for the underlying data used in this report."
Yes, this is the sort of wording, Ms Page, that you put
in when you're going to do what I think has elsewhere
been described as a "desk-based audit" that says, "We're
just going to ask some questions and we're going to
believe everything we're told and we're not going to
actually dig into the forensically dig into the detail".
Yeah.
But I'm -- I hesitate to criticise a fine firm like
KPMG.
But it's not the sort of job that --
They're bigger than us and they'll beat me up!
-- you would have done?
No, not the sort of thing that we would have done, no.
All right, thank you very much.
Can I just ask you about -- we can take that
document down now. Can I ask you a little bit more,
though, about this, this subject of suspense accounts.
If it turns out, if it can ever be found out, that the
194
a branch level for some products. If you sell £100
worth of stamps -- Jo -- for cash, the double entry is
simple: less stock, more cash. £100, both sides. Not
a problem.
But if you're, as in Jo's case, if you have a £2,000
shortfall that, in a moment in time, becomes a £4,000
shortfall, that extra £2,000 has got to come from
somewhere and go to somewhere. There's no such thing as
an invented amount of money in a double-entry
bookkeeping system. It would have to go somewhere.
And when Jo pressed that button and her shortfall
doubled -- and she's not the only person that asserted
that -- if that truly happened, then the system invented
aone sided entry, and what it effectively did was said
to Jo, "You need to have £2,000 more in the till or in
the safe than you've actually got". But why?
So, in that context, it doesn't satisfy the test of
a double-entry bookkeeping system and also raised the
points about entries that were processed by other
bolted-on front-end systems, like the Forde
Moneychanger.
I was just about to ask you that as my final question,
which is: was that exacerbated by those systems -- so,
obviously, we've got the Electronic Point of Sale
System --
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Yeah.
-- which managed Post Office products like stamps, and
so forth, but then we've got these bolt-ons that fed
figures into Horizon, whether it be from Bank of Ireland
cashpoints, Lottery terminals, and I think you mentioned
Foreign Exchange, there may have been others. Did the
double-entry problem that you've described with the
2,000/4,000, was that made any worse from your
investigations when looking at those bolt-ons?
Well, the principle of double-entry bookkeeping -- I go
back to my training in 1966, a bit of a long time ago
but I can remember back that far -- is based on
transactional double entry. You don't enter batches of
transactions, as you do with Lottery, the following
morning, or ATMs, processed at 4.30 in the afternoon, or
Foreign Exchange transactions processed on a Wednesday
once a week.
You can't assert that to be Horizon double entry.
These are block entries that are passed. So to claim
the benefits of double-entry bookkeeping in relation to
those front-end, bolt-on systems, I think is unsafe.
Do I understand this rightly: that, if they had been
being processed in realtime, they would have stood
a much better chance of being true double entry but,
because there was this once-every-period batch entry of,
197
Mediation Scheme was a scheme which was operated by all
concerned in good faith.
You were very much part of the core of people
engaged in the operation of that scheme. Two questions,
really: first of all, is it right that the idea of the
Scheme came from the Post Office?
Yes. Yes. I think from Susan Crichton, my
understanding.
‘SIR WYN WILLIAMS: = Right. Contemporaneously with your
‘operation of the Scheme, ie at the time, did you gain
any or did you have any idea about whether or not you
were engaged in a scheme which was being operated by all
concerned in good faith or whether Post Office were
engaged in a scam?
Well, call me naive, sir, but, I mean, we would not
have -- I would not have wasted the time of my team, my
‘own and my team's time, pursuing something that we'd
recognised from the outset was a waste of time. We
actually -- I now regard as pretty naive about this,
I kick myself, but it looked like a legitimate process
until, eventually, we realised that it wasn't. It was
just -- I mean, it was much later that we learned about
the phraseology of “only the expectation that token
payments would be made".
I think it was Sir Alan Bates that twigged that, in
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say, Lottery transactions, that caused problems?
A. Well, yes, in theory. But, I mean, the issue on, for
example, foreign exchange transactions is -- when
I asked Post Office for a copy of the Forde Moneychanger
user manual to be able to work out how the accounting
was working, they said they hadn't got one. I had to
re-reverse engineer the foreign exchange accounting from
the 2,500 pages of documents supplied to me by one of
the subpostmasters' professional advisers, as opposed to
the three documents that Post Office had supplied in
that case.
MS PAGE: Well, thank you. Those are my questions,
Mr Warmington.
Thank you, sir.
Questioned by SIR WYN WILLIAMS
THE WITNESS: Thank you.
SIR WYN WILLIAMS: = Mr Warmington, I think I should ask you
a few questions along the following lines, so please
bear with me.
Some of the senior executives and, I believe,
Ms Perkins, in particular, as Chair, were asked the
question -- or the suggestion was put to them, I think
is a better way of putting it -- that the Mediation
Scheme was a scam, all right? They denied that and, in
effect, told me that, so far as they were concerned, the
198
the vernacular, and realised that it was a sham well
before I did. I apologise for my stupidity.
SIR WYN WILLIAMS: Well, I wasn't asking you the question,
really, to, in any sense, be critical of you but rather
to gain an insight into how you viewed things at the
time. All right? So is the answer to my question that,
for much of the time, during which you were involved in
the Mediation Scheme, you did think that it was being
operated in good faith but there came a point in time
when you began to doubt that; is that a fair summary of
what you're telling me?
A. Yes, it is, and when we realised -- as soon as we
realised the POIRs were taking an awful long time to get
to us and, when they arrived, none of them gave an inch
in regard to any improper conduct or poor behaviour or
mistakes made by Post Office itself, we sort of twigged,
we realised, that this was going through a filtering
process that was filtering out any admission by Post
Office. I think, at that point, we realised that we
were -- that it was a waste of time.
SIR WYN WILLIAMS: Just so that I can try and put things
into sequence, how, or rather when did you form that
view, say, in comparison with when the schemes ceased to
operate at all?
A. Well, by the time we got to round about October 2014, it
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‘SIR WYN WILLIAMS:
The Post Office Horizon IT Inquiry
was just open warfare, so it was well before that. Go
back to sort of January/February 2013, it was running
quite well. On the departure of Susan, it took a marked
turn for the worse. So I would say by early
certainly by January -- by year-end 2013, we were
realising that it had become dysfunctional in the
extreme, so badly that I was prepared to pull stumps and
pull the team out but --
I've heard about two issues, which were
clearly thorny issues to be grappled with. One was the
expectation gap, as it's been called, namely that, on
the one side, subpostmasters who suffered significant
losses expected to have proper compensation, whereas, on
the Post Office side, the expectation was that the
compensation would be much lower. So that was thorny
issue number 1.
Thorny issue number 2, as I see it -- so tell me if
I've got it wrong -- was the very significant debate
which took place as to whether or not convicted people
should be mediated with at all. Were those the two
major difficulties?
A. Well, they certainly were two major difficulties. Yes.
The second one, and dealing with that first, it was just
obvious -- it was obvious to everybody that the
principal driving force for the -- for calling us in and
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A. Oh, yes.
SIR WYN WILLIAMS: Last question: what were the other major
difficulties which caused it, in the end, to founder?
A. It was the lawyering up, and the worst problem was the
lawyering up. This fact that I harboured the suspicion,
I think Mr Henderson probably shares this, that the two
teams of -- I'll call them investigators, they weren't
really -- the people that were preparing the POIRs on
a reporting line to Angela van den Bogerd, I met some of
those people: lovely people and they were empathetic
towards the postmasters' cases.
I strongly suspect that the reports they were
producing contained quite a few acknowledgements of
failings by Post Office and yet none of them that got
through to us had any such concessions and we would have
to be pretty thick not to notice that. We did, and my
suspicion -- and I think this is probably the case -- is
that it just went through a filtering process to remove
anything that was in any way an admission of failure,
let alone guilt, by Post Office.
So the work, the good work, that those people were
doing, I think, was filtered through Cartwright King and
Bond Pearce, and the offices of Rodric Williams and
Belinda, Aujard and others, into such an anodyne
response as to completely dismiss any assertions that
203
ONOaARWN
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23
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©NOORON
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12
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18 June 2024
carrying out an investigation, was -- had resulted from
a meeting between Lord Arbuthnot and Alice Perkins
before -- I think before she became Chairman and there
was this agreement to proceed, and it's absurd to think
that Lord Arbuthnot would have said, "Oh, and it's
perfectly okay if you leave Jo Hamilton and anybody else
out of this".
I mean, he'd made it completely clear that people
with convictions of any sort should be entitled to
benefit from the Mediation Scheme. But the corruption
of the Mediation Scheme, this expectation gap -- the
first point that you asked, sir -- when we started to
see the CQRs, the case questionnaire responses, the work
done by the professional advisers, including Howe+Co and
others, when we started to see those coming in with
pretty big numbers attached, it didn't surprise
Mr Henderson and myself at all. Some of the numbers
were quite big but it didn't surprise us but we, of
course, hadn't been told at that point that Post Office
was harbouring the view that they were only expecting to
make token payments. They never said that to us. If
they had, we'd have said, "Well, what are you smoking?”
SIR WYN WILLIAMS: So I've identified two major
difficulties. You say they were two of the major
difficulties.
202
the professional advisers were making, or that we
ourselves were making. Sorry, that's a very long answer
to a short question.
SIR WYN WILLIAMS: No, that's very helpful, thank you.
That's it, Mr Warmington, I assume, since I usually
have the last word, if anybody is going to have the last
word.
So thank you very much for making two witness
statements. Thank you for giving oral evidence this
afternoon, I'm very grateful to you and I'm sorry
I prolonged your stay by about ten minutes, unusually
for me, by asking a number of questions.
So I think we'll adjourn now until tomorrow and
start again at 9.45, Mr Beer?
MR BEER: Yes.
THE WITNESS: Thank you, sir.
MRBEER: Thank you very much.
THE WITNESS: Thank you, Mr Beer.
(4.40 pm)
(The hearing adjourned until 9.45 am the following day)
204
(51) Pages 201 - 204
The Post Office Horizon IT Inquiry 18 June 2024
INDEX
IAN RUTHERFORD HENDERSON (sworn) .....
Questioned by MR BEER ..
Questioned by MR STEIN .. 93
Further questioned by MR BEER 104
Questioned by SIR WYN WILLIAMS ..... 107
RONALD JOHN WARMINGTON (affirmed) ...... 109
Questioned by MR BEER ... 109
Questioned by MR STEIN .. 176
Questioned by MS PAGE 192
Questioned by SIR WYN WILLIAMS ..... 198
205
(52) Pages 205 - 205
MR BEER: [31] 1/3
1/5 118 28/22 50/17
50/21 50/25 51/3 83/6
83/10 83/14 83/16
93/9 104/12 104/16
107/19 108/23 108/25
109/4 109/6 109/9
154/12 154/18 154/21
154/25 155/2 174/14
175125 176/9 204/15
204/17
MR STEIN: [7] 93/15
102/14 102/16 102/20
104/9 176/12 191/22
MS PAGE: [3]
191/24 192/3 198/12
SIR WYN WILLIAMS:
[37] 1/4 26/25 28/10
28/21 50/20 51/2 83/9
83/15 93/13 102/11
102/15 102/19 104/11
104/14 107/22 108/8
108/14 108/22 108/24
109/5 154/16 154/19
155/1 174/18 175/4
175/21 176/5 176/10
192/1 198/17 199/9
200/3 200/21 201/9
202/23 203/2 204/4
THE WITNESS: [6]
108/21 175/24 191/23
198/16 204/16 204/18
$
$500 [1] 185/13
43 [1] 17/14
"14 [1] 168/7
"45 [2] 29/14 168/7
"66 [2] 110/23 111/3
"68 [1] 110/25
‘arm's [1] 89/21
"Black [1] 6/7
‘clients’ [1] 137/15
"Defend [1] 93/4
‘Draft’ [1] 152/22
expert’ [1] 166/19
"get [1] 149/6
"Having [1] 36/20
‘Horizon’ [3] 6/6 15/2
15/7
"lawyer [1] 92/24
‘light [4] 92/16
‘Local [2] 22/24 27/5
"marking [1] 159/6
‘mild’ [1] 137/18
‘missing’ [1] 103/8
‘no’ [2] 60/20 162/16
‘POID' [1] 152/15
‘Post [1] 39/13
“presumption [1]
150/24
‘Receipts [5] 22/23
23/3 25/20 27/4 27/9
"Security [3] 39/14
42/9 43/5
"seeking [1] 150/25
"systemic [4] 123/6
125/8 130/15 130/23
‘that [1] 159/11
‘the [4] 2/3 2/4 91/25
101/9
‘Tunnel [1] 151/4
"Well [1] 159/13
‘will [1] 41/4
"you're [1] 157/18
IAF [4] 76/25
0
01 [1] 31/25
012 [3] 32/4 36/16
44/10
02 [1] 31/25
03 [1] 31/25
=
1 August [1] 99/7
1 June [1] 4/22
1.25 [1] 94/14
1.55 [2] 108/23 109/3
10 [4] 20/10 52/17
65/16 140/20
10 June [1] 110/7
10 years [1] 104/7
10,000 [3] 182/11
187/9 187/14
100 [2] 196/1 196/3
100,000 [2] 98/16
189/21
102 [1] 177/11
106 [1] 166/16
107 [1] 171/3
108 [1] 172/25
14 [3] 81/12 188/13
188/15
11,000 [1] 185/18
11,500 [4] 20/17
11.00 [1] 50/18
11.01 [4] 50/22
11.10 [1] 50/19
11.11 [1] 50/24
410 [1] 173/20
114-page [1] 119/10
12 [10] 20/10 44/4
44/15 44/16 48/9
52/17 78/19 110/8
149/10 189/1
12 months [1] 87/1
12 pages [1] 109/14
12,000 [1] 188/2
12,000-odd [1] 131/7
12.05 [2] 83/7 83/11
12.15 [2] 83/8 83/13
12.54 [1] 109/1
13 [5] 44/14 44/15
44/16 65/13 65/13
13 September [4]
68/15 68/23 71/11
77/7
136 [1] 191/13
14 [2] 44/14 105/2
14.10 [1] 63/25
140 [1] 14/7
142 [1] 88/2
15 [3] 44/14 132/5
169/14
15 July [4] 104/23
105/4 168/7 170/1
150 [2] 117/14 127/4
159 [2] 89/11 89/13
16 [4] 44/14 57/17
132/5 133/14
16 January [2] 102/9
102/23
160 [1] 90/17
161 [1] 91/16
162 [1] 91/17
163 [2] 1/22 91/17
47 [1] 14/23
17 May [2] 33/13
36/11
17 May' [4] 39/14
17 pages [1] 79/10
18 [3] 117/21 117/24
128/10
18 June 2024 [1] 1/1
18,000 [1] 182/9
19 [4] 137/12
19 October [1] 40/24
19,000 [2] 182/10
183/22
1966 [2] 110/23
197/11
1968 [4] 110/21
1971 [1] 110/15
1975 [2] 110/21
111/7
1979 [4] 110/17
1980 [1] 2/21
1996 [1] 88/20
2
2 June [2] 38/24
41/22
2,000 [3] 196/5 196/7
196/15
2,000/4,000 [1] 197/8
2,500 [1] 143/5
2,500 pages [1]
198/8
2-3 [3] 60/10 60/13
162/3
2.05 [1] 154/13
2.2 [1] 68/14
2.20 [1] 154/14
2.47 [1] 95/25
20 [5] 109/15 109/17
109/19 138/5 148/1
20 May [1] 1/16
20-something [1]
128/21
2000 [1] 111/15
2002 [1] 111/7
2004 [2] 56/6 144/24
2006 [6] 33/13 36/11
55/19 56/8 145/3
182/25
2008 [1] 67/10
2009 [1] 111/19
2010 [6] 26/1 26/6
55/21 64/3 111/15
111/19
2010/2011 [2] 189/14
189/22
2011 [2] 189/14
189/22
2012 [41] 3/19 4/2
4/15 4/22 5/4 18/19
40/24 47/21 49/7 49/8)
50/10 51/3 51/8 51/14
52/6 54/1 58/5 58/19
59/21 62/14 65/14
68/15 68/23 71/7
71/11 76/7 76/16 77/8
79/12 107/3 107/7
116/7 133/16 140/20
147/10 148/7 155/15
160/12 160/19 164/12
164/25
2012/2013 [1] 167/5
2013 [35] 16/17
22/25 23/15 27/6
27/19 28/13 29/10
59/25 62/18 81/11
87/7 104/23 105/4
107/25 115/8 115/11
117/7 133/21 140/22
144/21 148/7 152/9
157/3 157/21 160/21
161/12 161/15 161/19}
167/5 168/7 168/7
168/24 170/1 201/2
201/5
2014 [16] 29/11
29/12 42/11 94/11
100/9 100/13 139/12
139/17 139/23 140/1
140/4 152/20 174/21
174/22 175/3 200/25
2015 [11] 28/9 35/23
38/24 39/25 102/10
102/23 103/17 130/7
171/19 173/3 174/24
2018 [1] 68/11
2020 [4] 3/18 168/16
191/9 192/9
2021 [4] 135/9
2024 [4] 1/1 23/6
109/16 110/7
21 [2] 87/4 155/4
212 [1] 189/21
22 [4] 4/20 112/19
121/12 140/18
22 July [1] 81/11
22 May [1] 61/9
23 [2] 10/17 10/18
24 hours [1] 185/25
24 March [2] 35/23
39/10
25 [5] 22/19 22/20
23/11 27/3 141/22
26 [1] 17/10
26 October [1] 130/6
27 July [1] 76/7
28 [5] 84/18 122/23
122/23 124/25 125/2
28 September [1]
68/11
29 [2] 128/10 148/1
29 September 2010
[1] 26/6
3
3 June [1] 41/22
3 March [1] 173/3
3 years [1] 94/19
3-year [1] 94/17
3.08 [1] 154/22
3.20 [2] 154/15
154/21
3.21 [1] 154/24
3/5 [1] 101/4
30 [1] 83/17
30 July [2] 94/14
139/25
300 million [1] 86/2
31 [4] 76/20
34 July [1] 95/25
32 [1] 21/11
34,000 [1] 28/1
36 [2] 20/12 21/12
38 [1] 48/10
39 [2] 48/9 48/11
4
4 July [2] 6/22 8/15
4,000 [2] 196/6 197/8
4.10 [3] 36/9 39/12
40/3
4.11 [2] 37/7 39/14
4.30 [2] 191/25
197/15
4.40 [1] 204/19
40 years [1] 173/17
400 years [1] 88/16
44 [1] 117/20
43 [3] 65/12 65/13
77/11
44 [2] 65/20 69/5
45 [1] 84/4
46 [2] 66/11 155/6
47 [2] 66/21 128/11
48 [1] 67/2
49 [6] 128/9 128/13
140/22 150/3 166/16
(63) MR BEER: - 49
40
49... [1] 166/16
5
5 August [3] 100/9
100/11 100/13
5,000 [2] 182/12
187/14
50 million [1] 185/15
50/49 [1] 128/9
500 million [1]
185/14
500,000 [1] 7/14
53 [3] 57/17 57/18
88/1
54 [4] 109/23
54 pages [1] 109/14
55 [1] 14/23
58 [3] 89/12 122/22
125/2
59 [4] 1/22
6
6 August [1] 100/10
6 June [3] 5/4 6/10
133/16
6 May [1] 39/25
60 [2] 1/17 2/13
60 pages [1] 1/16
612,000 [2] 189/15
190/16
7
7 September [1] 51/8)
7 years [1] 76/19
7.30 [1] 185/11
700 [1] 20/18
700-odd [1] 47/13
74 [1] 121/13
77 [2] 22/21 27/2
78 [4] 17/10
8
8 February 2014 [1]
139/17
8 July [5] 16/17
62/18 107/25 117/6
123/20
8.1 [1] 123/21
8.2 [2] 128/3 129/7
88 [1] 84/17
9
9.45 [3] 1/2 204/14
204/20
A
abbreviation [2]
135/10 135/11
abeyance [1] 164/17
ability [3] 67/11 71/2
155/17
able [23] 22/15 41/12
47/15 51/21 64/21
64/23 77/22 84/25
95/19 97/20 101/24
114/17 114/18 117/17)
141/21 142/7 153/7
175/1 184/1 189/8
191/25 192/10 198/5
about [138] 8/5 8/18
8/21 13/25 14/6 17/18)
18/9 20/9 20/21 25/8
25/16 25/17 25/22
26/13 26/14 27/12
28/19 31/3 38/24
39/15 40/20 42/14
46/9 47/14 48/7 48/21
49/24 50/3 50/10
53/21 54/8 54/13
54/19 54/21 55/8
55/16 55/17 55/19
55/20 56/17 58/7 59/2
60/22 61/5 61/18
61/23 61/25 62/9
62/23 66/15 67/2
68/22 69/16 69/17
70/5 73/12 74/2 75/5
75/23 77/12 81/18
82/12 84/21 85/11
85/21 86/9 86/15
86/17 87/7 91/16
91/18 93/19 105/18
107/14 112/15 113/20)
115/4 115/8 119/2
121/3 122/24 126/13
128/9 128/20 130/1
138/7 139/12 139/23
140/4 142/13 146/5
147/6 147/20 147/22
151/22 152/14 154/8
155/13 157/19 163/41
163/5 163/6 164/11
167/21 169/17 172/14)
173/17 174/20 176/14)
177/15 178/24 179/13
184/9 184/19 184/20
184/24 187/20 189/13)
189/20 190/3 190/3
192/4 192/17 193/12
194/22 194/24 195/11
195/14 195/15 195/18)
196/19 196/22 199/11
199/19 199/22 200/25)
201/9 204/11
above [4] 39/8 61/21
88/18 143/18
absence [1] 143/19
absent [2] 141/23
172/8
absolutely [4] 80/6
129/10 146/1 173/15
absorbing [1] 195/1
absurd [7] 46/5
126/11 138/4 164/5
165/6 165/8 202/4
abundantly [1]
163/22
abuse [1] 131/25
accept [5] 76/3 92/15
97/12 167/22 194/6
accepted [5] 124/4
136/18 138/8 153/20
172/20
accepts [1] 92/10
access [42] 17/20
19/10 26/2 43/15
43/17 47/7 47/9 47/11
47/15 49/14 53/1 53/4
53/17 56/25 57/10
59/7 59/10 63/20
65/22 68/24 69/7
69/17 69/21 70/7
70/10 70/15 71/9
71/10 71/13 71/21
81/4 112/10 112/12
112/12 112/15 112/21
115/6 115/21 145/17
155/11 156/10 183/12
accessing [2] 66/2
71/6
accident [1] 129/14
accidentally [1]
47/22
accommodate [1]
121/10
accompanied [1]
32/15
accordance [1] 43/6
According [1] 112/18
account [28] 22/24
30/12 30/25 70/2
70/18 94/14 94/18
94/19 95/5 95/11 97/1
97/2 97/9 97/17 97/21
98/16 98/18 98/20
99/2 99/9 99/12
101/22 103/8 103/9
181/22 183/7 189/7
190/13
accountability [1]
91/16
accountable [1]
187/22
accountancy [1]
186/25
accountant [4] 2/22
110/15 112/2 187/2
accountants [7] 2/25
7/25 11/17 136/20
155/19 188/9 191/20
accounted [1]
184/15
accounting [17] 9/10
9/18 34/5 36/21 37/19
48/13 96/16 97/3
97/10 98/10 98/23
121/24 143/24 148/20}
149/7 198/5 198/7
accounts [40] 67/11
71/14 71/22 93/20
94/1 95/1 95/10 96/14
97/25 98/2 98/9 98/13
99/20 101/10 101/25
103/3 103/23 104/3
176/14 180/6 180/10
181/2 181/4 181/7
181/8 181/14 182/20
182/25 184/5 184/6
184/18 184/20 184/21
185/6 188/14 188/19
189/13 191/1 191/21
194/24
accuracy [2] 73/1
194/5
accurate [7] 7/17
69/12 152/12 152/17
152/25 153/11 174/5
accurately [3] 9/4
9/15 87/7
accusations [1]
116/15
accused [2] 143/24
149/23
acknowledge [1]
185/22
acknowledged [1]
127/18
acknowledgement
[4] 119/24
acknowledgements
[1] 203/13
acquired [2] 110/22
111/4
acquiring [1] 140/13
acquittals [2] 56/17
143/21
acquitted [1] 57/13
across [14] 29/4
30/14 31/22 85/8 91/5
101/10 119/21 128/13}
159/23 167/25 168/1
173/23 173/25 183/18
Act [1] 88/20
acted [2] 76/13
167/24
acting [1] 84/20
action [6] 9/2 35/9
84/24 112/16 119/11
160/23
actions [1] 89/7
activities [1] 76/18
activity [4] 103/16
actors [1] 172/3
acts [1] 137/4
actually [24] 6/14
11/8 18/22 21/10
22/11 27/15 28/16
47/25 67/7 67/14 82/9)
126/4 160/16 160/18
163/18 164/7 168/13
188/3 192/4 193/13
193/14 194/13 196/16}
199/19
adapt [1] 121/4
add [2] 25/1 187/18
added [2] 169/17
169/20
additional [2] 8/5
138/22
address [8] 91/1
100/15 103/7 112/7
123/10 132/12 171/14)
171/16
addressed [2] 35/12
127/11
addresses [2] 105/5
106/7
addressing [1]
127/17
adequacy [1] 155/17
adequate [2] 142/16
181/19
adequately [1]
122/20
adjourn [1] 204/13
adjourned [1] 204/20
Adjournment [1]
109/2
administrative [1]
22/18
administrator [1]
22/7
admission [3] 148/19
200/18 203/19
adopt [1] 18/15
adopted [1] 16/16
adrift [1] 141/21
Advanced [1] 77/2
adversarial [2] 47/4
103/4
adverse [1] 113/20
advice [21] 21/22
35/6 42/21 52/19
58/25 79/15 85/20
99/22 104/22 104/23
105/5 105/25 106/7
106/9 106/13 106/15
160/21 160/24 168/7
168/15 170/1
advise [2] 15/1 15/5
advisedly [1] 131/24
advisers [4] 39/23
198/9 202/14 204/1
AF [3] 76/25 77/1
77/2
affairs [1] 179/24
affected [3] 71/13
179/24 181/2
affirmed [2] 109/7
205/12
afford [1] 85/1
afraid [7] 49/2 151/10)
151/14 159/15 161/9
164/10 171/22
Africa [2] 111/12
111/17
after [20] 10/8 16/19
23/15 38/25 43/12
53/11 55/6 90/14
(64) 49... - after
A
after... [12] 106/25
114/1 123/15 127/2
136/9 139/13 153/5
155/8 170/12 172/7
184/6 189/5
afternoon [12] 83/14
83/16 93/15 94/11
108/19 109/4 109/9
154/14 154/25 155/3
197/15 204/10
afterwards [3] 66/18
129/19 159/24
again [29] 9/4 9/15
16/1 21/4 22/21 25/9
29/7 31/15 33/16
50/13 59/23 61/22
70/19 71/5 73/7 96/4
102/3 102/4 102/5
107/22 108/4 116/6
120/23 139/25 150/16)
154/2 164/22 184/22
204/14
against [8] 9/24
39/17 45/20 84/24
112/16 116/15 142/25}
145/12
agents [2] 114/18
187/21
aggregate [1] 190/16
aggregated [1]
189/15
aggressive [1] 85/8
ago [3] 12/14 104/7
197/11
agree [17] 12/5 12/7
12/10 37/25 60/8
71/10 73/15 93/6
93/24 97/7 100/21
126/16 162/1 162/12
179/10 179/25 180/1
agreed [8] 34/10 60/7
83/18 83/25 84/10
126/23 161/25 164/19
agreement [9] 38/7
78/20 84/25 139/15
139/25 177/2 177/7
177/7 202/4
agreements [2] 13/1
13/1
Ah [2] 146/17 184/8
ahead [1] 136/5
aim [1] 150/25
air [1] 95/4
airbrushed [1] 46/1
Al [2] 103/16 131/17
Alan [13] 2/2 2/10
2/12 2/12 10/19 16/1
16/3 91/24 129/18
129/22 179/10 183/14
199/25
albeit [2] 16/19 64/24
alerting [1] 165/17
Alice [4] 5/4 112/24
134/24 202/2
Alisdair [1] 102/9
alive [4] 11/23
all [58] 4/7 5/23 17/8
21/8 28/21 30/15
31/12 31/19 32/18
41/3 41/15 48/22
55/18 58/3 73/8 79/10)
80/5 85/25 93/4
100/22 101/15 102/13)
104/14 105/21 107/20)
108/14 114/23 117/11
126/6 127/10 127/25
129/23 130/21 133/7
137/10 137/13 137/22)
143/18 157/6 158/4
159/13 175/21 176/16)
179/5 180/8 182/14
187/23 192/21 194/21
195/15 198/24 199/1
199/5 199/12 200/6
200/24 201/20 202/17
allegation [1] 67/8
allegations [3] 79/18
142/1 150/9
alleged [2] 38/9
143/22
allegedly [1] 191/20
Alliance [1] 10/21
allocated [3] 95/17
97/15 97/18
allow [3] 16/24
141/15 171/6
allowed [5] 80/22
87/18 125/10 172/23
181/9
allows [1] 178/12
almost [8] 72/16 82/9
82/15 118/17 119/18
147/15 147/18 147/19)
alone [1] 203/20
along [11] 31/17 76/9
101/9 114/5 125/16
126/20 146/24 159/10)
159/12 193/8 198/18
alongside [2] 44/2
124/22
already [16] 55/2
55/15 55/17 60/21
61/22 61/25 72/24
84/5 102/8 133/2
141/5 144/17 158/12
164/22 165/9 170/13
also [35] 14/15 17/17
20/2 20/25 48/12
65/24 66/22 69/21
69/21 74/21 77/13
78/14 79/21 89/24
90/11 92/5 93/25
96/11 97/21 98/24
108/12 122/8 138/4
143/8 148/13 153/10
153/11 156/16 171/12)
179/21 181/9 182/20
189/16 195/18 196/18}
alter [1] 67/11
alternative [5] 91/12
98/14 98/17 98/17
181/23
although [8] 12/15
39/5 77/21 122/1
123/12 135/17 137/15
154/4
Alun [1] 173/8
always [11] 7/21 10/6
12/22 67/23 80/12
125/21 175/15 182/24
183/3 188/19 192/23
Alwen [8] 57/4 60/4
72/12 73/17 75/2 81/9
134/19 134/24
Alwyn [2] 66/12
79/22
am [13] 1/2 27/20
42/12 42/25 50/22
50/24 79/20 103/5
122/5 133/20 142/21
151/3 204/20
Amanda [1] 151/18
ambitious [1] 85/8
amendment [1] 2/6
America [1] 185/14
among [1] 170/20
amount [9] 99/16
101/9 117/18 129/14
136/6 183/6 188/17
189/20 196/9
amounts [12] 85/23
94/20 98/6 184/17
186/21 188/14 189/7
189/17 190/8 190/19
191/15 193/15
amusing [1] 179/13
analyse [1] 97/20
analysed [2] 34/4
36/20
Analysing [1] 98/19
analysis [1] 142/3
Andrew [3] 39/6
95/24 138/5
Andy [3] 48/5 99/17
100/21
anecdotal [1] 119/13
Angela [9] 51/20 57/5I
89/6 94/12 96/5 96/6
99/8 172/2 203/9
angry [1] 138/7
annex [1] 47/24
annually [1] 179/23
anodyne [1] 203/24
anomalies [1] 149/2
anomaly [1] 72/8
another [7] 78/10
88/6 100/15 102/7
170/25 175/21 184/15]
answer [34] 22/15
35/7 54/11 60/13
60/19 61/14 61/18
81/2 100/19 101/19
102/16 103/23 103/25}
126/6 133/1 133/6
140/12 142/7 142/9
142/17 143/11 146/2
162/3 162/16 163/1
164/17 165/3 170/18
172/25 191/4 191/6
191/6 200/6 204/2
answered [6] 122/20
163/20 164/6 164/22
176/16 193/19
answering [4] 79/2
80/25 171/4 192/7
answers [3] 93/23
103/24 113/6
Anthony [3] 116/19
180/20 184/11
any [114] 6/7 8/11
11/9 11/15 14/13
14/19 15/2 15/6 16/8
16/13 16/14 18/3
24/14 26/13 29/6 31/6
34/5 35/14 35/15
36/21 41/5 41/6 42/21
43/23 50/3 52/10 54/5)
54/18 54/19 56/1
58/19 59/16 60/25
61/4 71/15 72/5 72/9
72/13 73/3 75/2 76/14
78/22 79/24 80/9 83/5)
85/5 91/7 92/15 95/4
99/20 106/17 107/10
107/11 107/13 111/3
117/18 120/2 121/1
130/19 133/23 135/20}
138/9 140/10 141/23
142/15 142/23 143/9
143/13 143/17 144/5
145/5 145/15 148/11
149/4 149/9 149/20
150/6 150/8 154/19
157/2 159/20 163/25
165/5 172/12 173/1
174/19 175/9 175/22
178/10 184/20 185/17}
185/21 185/25 188/17,
188/18 189/17 193/15)
193/18 193/23 193/23}
193/24 194/4 194/6
195/12 197/8 199/11
199/11 200/4 200/15
200/18 202/9 203/15
203/19 203/25
anybody [5] 90/15
140/15 172/11 202/6
204/6
anyone [9] 39/22
74/6 100/1 106/14
130/11 145/23 151/4
169/2 178/8
anything [15] 28/18
50/10 84/22 100/22
101/15 107/23 114/7
146/15 150/7 154/8
171/5 173/23 176/21
192/16 203/19
anyway [3] 20/19
161/1 176/5
anywhere [2] 182/15
193/4
apart [1] 195/13
apologise [3] 70/10
125/11 200/2
apparent [4] 48/17
49/16 63/10 172/16
apparently [2] 138/9
151/23
Appeal [1] 168/14
appear [3] 71/20
148/24 193/9
appeared [2] 62/24
115/23
appears [2] 64/2
150/23
appended [4] 39/18
40/4 40/25 41/9
applicant [9] 29/24
30/9 37/19 37/25 39/8
39/17 40/1 40/7 88/10
applicant's [5] 30/7
30/19 31/1 37/3 40/16)
applicants [1] 117/1
applicants’ [1] 127/4
application [1] 26/14
applications [2]
88/13 127/23
appointed [8] 5/21
11/7 11/16 13/16
46/24 89/23 103/16
136/20
appointment [5] 3/20
4/13 10/9 10/19 11/2
appreciate [1] 71/25
approach [8] 7/12
31/15 46/20 51/25
52/3 78/12 78/14
118/20
approached [3] 4/15
52/12 82/14
appropriate [2] 73/19]
127/17
appropriated [1]
103/9
appropriateness [1]
194/5
approve [1] 159/11
approved [3] 53/2
137/13 145/18
approximate [2]
49/10 79/10
approximately [1]
65/16
April [1] 87/7
Arbuthnot [8] 12/4
81/10 83/24 116/18
122/13 160/3 202/2
(65) after... - Arbuthnot
A
Arbuthnot... [1]
202/5
Arbuthnot's [1] 92/5
arcane [1] 132/23
Arch [2] 57/13 144/1
architect [2] 67/25
72/2
architects [1] 73/10
architecture [2]
68/21 76/25
archives [2] 67/5
67/16
are [81] 2/14 2/17
11/3 11/4 14/2 25/21
38/11 38/14 41/1
41/14 41/16 51/12
52/1 52/1 52/17 57/9
60/6 61/12 61/17 63/2
64/7 71/3 79/24 81/8
92/20 92/22 92/23
93/1 93/10 93/11 95/4
95/7 96/4 96/11 96/13
96/16 96/23 98/1 98/3,
101/23 105/23 110/2
110/5 110/10 110/12
111/24 121/7 128/4
130/12 130/13 130/18}
131/19 131/20 139/9
141/23 143/14 147/3
148/9 148/19 149/18
151/6 152/7 153/3
161/24 162/8 162/20
162/25 165/4 172/6
174/14 174/15 174/18)
174/20 184/19 187/2
188/21 190/20 197/19
197/19 198/12 202/22
area [9] 19/7 19/9
50/8 58/24 63/18 72/3
93/21 93/23 93/25
areas [4] 62/21 63/14
176/12 177/1
arguable [1] 18/8
arising [1] 130/20
Army [1] 2/20
arose [1] 29/9
around [10] 22/9
42/11 79/20 99/16
119/5 122/10 140/20
154/9 163/18 173/20
ARQ [3] 76/21 78/7
78/19
arrive [2] 150/18
177/25
arrived [2] 118/5
200/14
art [1] 186/25
articles [1] 143/2
articulated [3] 83/22
83/24 150/15
as [277]
ashamed [1] 172/23
aside [3] 106/14
126/24 151/13
ask [29] 1/10 70/8
71/17 93/10 93/19
100/1 104/13 104/17
104/18 109/10 122/3
126/13 146/4 157/24
183/8 190/22 194/11
194/22 194/23 195/18)
195/21 196/22 198/17)
asked [34] 8/25 21/8
45/19 54/10 58/2
67/17 89/14 90/6
94/23 99/12 100/23
102/5 103/18 122/12
124/19 125/14 126/8
127/6 146/25 147/18
153/5 153/12 153/15
153/16 153/16 171/11
174/18 184/12 190/22)
192/4 192/24 198/4
198/21 202/12
asking [7] 13/4 28/17
60/23 165/2 176/23
200/3 204/12
aspect [1] 80/19
aspects [1] 86/9
assert [2] 39/24
197/18
asserted [2] 46/4
196/12
asserting [1] 119/5
assertion [2] 46/5
195/24
assertions [3]
148/25 150/14 203/25)
assess [1] 155/17
assessed [1] 63/3
asset [1] 149/11
assigned [1] 115/21
assist [1] 38/4
assistance [6] 81/3
112/20 115/5 149/21
177/12 177/13
assisting [1] 3/21
associate [1] 84/1
associated [2] 38/1
135/16
assume [3] 25/15
49/22 204/5
assurance [1] 194/4
assurances [2] 66/15]
72/113
assured [2] 10/24
75/6
astonished [1] 159/9
astonishing [1]
34/14
astute [1] 129/23
at [351]
at page 2 [1] 161/17
Atkinson [1] 165/19
162/12 171/21 174/14)
175/23 176/24 180/25)
ATM [2] 141/11 188/41
ATMs [1] 197/15
attach [1] 42/11
attached [3] 40/18
153/9 202/16
attempt [6] 16/8 68/6
87/11 88/25 121/19
126/6
attempted [3] 54/14
88/4 142/8
attempting [1] 87/9
attempts [1] 140/10
attend [1] 90/9
attended [1] 68/17
attending [1] 6/24
attention [12] 17/1
90/19 127/4 140/16
144/4 148/25 156/7
173/2 191/12 191/17
192/17 195/16
attitude [7] 16/11
46/23 47/3 63/16 88/7
92/19 107/1
attitudinally [1]
115/21
attributed [3] 2/2
91/24 152/1
audience [2] 91/15
103/4
audit [10] 42/13
66/15 73/5 75/7 76/18
78/8 111/10 111/11
188/12 194/10
auditing [1] 186/2
auditor [2] 110/21
186/14
auditors [1] 191/19
August [17] 64/3
67/10 99/7 100/9
100/10 100/11 100/13
116/7 140/4 147/10
155/14 160/11 160/19}
163/4 164/12 164/24
175/3
August 2014 [1]
175/3
Aujard [19] 84/21
85/7 94/13 102/7
102/9 102/23 102/24
103/14 134/19 152/23
153/5 153/12 153/15
153/16 153/18 154/10}
172/1 172/8 203/24
author [1] 33/2
authored [1] 26/3
authority [1] 14/2
autonomous [1]
89/21
autumn [1] 168/23
available [20] 7/16
8/6 19/24 20/10 24/6
37/11 48/1 57/24
59/11 68/1 68/1 89/8
90/22 90/24 91/12
91/13 96/25 99/21
128/2 142/9
average [4] 101/4
101/7 101/18 102/2
averages [1] 101/11
avoid [5] 37/25
100/21 101/14 123/14}
130/24
avoided [2] 130/14
130/23
aware [28] 7/20 10/9
14/4 23/16 35/11 48/3)
55/2 61/4 61/4 63/17
69/21 71/25 79/24
87/22 93/16 95/8
102/14 107/9 130/13
134/12 143/20 144/17I
166/21 167/3 168/6
168/11 168/17 168/19
away [12] 17/1 75/21
87/9 87/12 88/5 88/25)
102/4 120/1 123/4
125/6 125/17 147/18
awful [2] 172/13
200/13
B
back [40] 1/22 10/15
15/12 17/11 18/18
34/19 50/13 51/3
51/21 52/25 57/21
61/9 63/12 65/11
69/22 73/20 76/1 78/3}
81/16 83/3 84/9 85/24,
99/11 132/2 137/11
157/17 161/2 161/6
161/10 163/14 164/12
167/5 175/14 178/14
182/22 191/11 192/21
197/11 197/12 201/2
back' [1] 149/6
back-end [1] 69/22
background [2] 2/19
110/13
backing [1] 112/6
bad [1] 173/23
badly [4] 2/4 92/1
179/24 201/7
Baker [24] 8/18
23/18 51/8 51/18 60/3)
61/10 61/15 64/17
65/8 66/23 76/9 76/13
79/5 79/14 80/8
106/21 108/4 108/8
115/20 117/13 144/20}
161/15 161/18 161/23
balance [2] 70/20
191/2
balances [9] 94/19
95/9 95/16 97/17 98/3)
98/20 101/21 181/12
188/18
balancing [1] 143/15
ballpark [1] 99/15
bank [7] 139/13
185/14 187/7 187/25
188/1 188/2 197/4
banking [1] 187/7
bankrupt [1] 85/2
barbed [1] 119/11
barking [1] 165/20
barrels [1] 164/8
barrister [4] 105/4
155/22 160/13 163/11
based [18] 7/12 9/25
9/25 10/5 10/5 18/22
26/18 47/12 48/25
57/22 65/17 128/11
128/18 148/9 148/21
182/7 194/10 197/12
basement [1] 67/9
basically [1] 78/6
basis [10] 3/10 37/11
40/17 42/21 46/18
52/9 129/1 136/1
148/14 164/13
bat [1] 163/14
batch [1] 197/25
batches [1] 197/13
Bates [8] 2/3 2/10
2/12 2/12 10/20 16/1
91/25 199/25
BDO [2] 56/8 145/1
be [246]
be a[1] 64/2
bear [6] 18/3 20/2
20/16 67/22 132/20
198/19
bearing [2] 20/23
97/14
beat [1] 194/18
became [11] 23/16
33/2 47/4 110/14
110/17 111/19 119/18)
124/8 133/11 174/23
202/3
because [49] 7/25
11/18 26/17 34/12
36/17 39/20 52/9 58/1
59/6 62/1 62/15 69/14
74/19 79/23 79/24
80/1 88/17 93/21
93/25 105/25 117/8
119/16 124/11 124/18)
126/17 128/13 129/20)
139/3 140/12 156/18
157/23 158/12 159/5
159/25 160/25 160/25)
174/7 174/10 174/22
175/15 176/1 178/25
181/12 185/12 188/4
188/7 189/20 193/6
197/25
become [5] 86/24
92/9 168/11 174/11
201/6
becomes [1] 196/6
becoming [2] 51/14
(66) Arbuthnot... - becoming
B
becoming... [1] 53/12
bedtime [1] 178/20
been [161] 2/4 8/25
9/10 15/16 20/20 23/8
23/20 26/9 26/16
27/19 30/21 32/24
34/6 36/1 36/4 36/22
37/3 37/8 37/15 37/18
37/24 38/4 38/18 43/2
43/17 44/21 45/5
48/12 48/20 49/19
49/20 57/13 61/24
64/21 67/1 72/1 73/3
74/3 74/5 75/6 75/23
76/11 89/14 89/25
90/14 90/20 90/21
92/1 93/22 93/24
95/17 98/12 101/24
102/22 104/2 104/8
104/20 104/24 105/18)
106/9 115/7 118/6
119/16 119/23 120/2
121/23 122/12 123/2
123/11 125/5 125/14
126/3 126/6 126/7
126/8 126/20 127/6
127/7 127/8 128/22
128/23 129/2 129/6
129/12 130/15 130/16
130/24 131/1 131/7
131/8 132/18 132/25
133/8 133/22 134/10
137/3 137/3 140/13
140/14 142/15 143/4
143/21 145/6 146/11
146/25 147/9 147/18
153/24 154/2 155/11
158/10 158/19 159/16}
163/4 163/25 165/6
165/10 165/10 166/21
167/3 167/6 168/4
168/19 169/8 170/5
170/16 170/20 171/18}
172/5 173/16 173/18
174/24 176/21 176/24}
177/6 179/4 180/2
181/13 184/9 188/9
188/12 189/8 189/9
189/19 190/1 190/5
190/17 190/17 190/19)
191/3 191/7 192/4
193/11 194/10 195/2
195/5 195/6 197/6
197/22 201/11 202/19}
BEER [24] 1/7 1/9
1/10 26/25 102/8
104/11 104/15 108/22)
109/8 109/10 109/18
117/8 124/17 126/3
142/4 158/1 164/10
172/19 176/16 204/14}
204/18 205/4 205/8
205/14
before [31] 3/2 22/25
26/2 26/25 27/6 27/13
27/19 28/14 28/20
48/8 52/2 65/1 106/1
108/3 111/22 118/13
129/19 129/20 134/16)
157/4 161/19 167/24
168/18 174/18 178/20}
190/25 195/11 200/2
201/1 202/3 202/3
began [2] 46/8
200/10
beginning [9] 16/7
17/21 18/18 51/12
83/22 132/3 139/20
144/5 154/16
behalf [12] 1/11 13/4
41/23 108/4 109/10
112/8 127/10 137/19
158/13 160/1 174/15
175/23
behaviour [2] 173/24
200/15
behind [3] 87/19
116/12 136/5
being [71] 7/1 11/2
11/7 12/24 12/24
28/24 32/22 34/23
42/19 43/13 51/16
53/14 57/19 57/24
64/5 64/22 65/7 66/9
66/19 71/11 71/15
73/14 73/17 74/21
75/11 75/16 80/24
85/25 89/19 92/20
94/23 95/10 95/21
96/7 97/7 97/15 97/18
97/20 98/8 99/3 100/4
100/20 101/13 102/11
103/13 103/20 105/4
106/14 106/21 115/6
131/22 138/12 142/7
150/9 153/23 153/25
154/1 154/1 156/15
163/19 163/19 180/4
188/4 188/10 190/24
191/2 191/15 197/23
197/24 199/12 200/8
belief [3] 2/16 110/4
110/11
believe [12] 11/21
13/12 52/4 68/18
93/25 107/24 136/9
155/14 189/22 192/9
194/12 198/20
believed [1] 136/15
Belinda [11] 94/12
96/5 96/6 99/7 99/8
100/13 100/14 100/21
152/24 172/1 203/24
belong [4] 41/3 95/2
95/5 95/6
belonged [2] 95/15
189/8
belongs [1] 39/21
below [4] 37/8 96/10
96/20 99/18
benefit [8] 41/2 79/21
129/16 149/15 158/8
158/19 167/16 202/10
benefits [2] 129/10
197/20
best [12] 2/15 9/20
67/4 77/12 77/119
99/22 110/3 110/11
135/14 146/23 166/5
170/14
bet [3] 160/8 186/11
186/24
better [14] 12/9
51/19 57/16 89/25
98/17 122/5 129/12
129/24 135/18 172/12]
184/5 185/15 197/24
198/23
between [23] 6/22
9/5 12/17 12/21 13/9
53/16 64/19 70/20
73/16 78/20 83/18
97/3 97/10 110/21
111/7 111/15 122/4
137/17 147/16 161/15}
185/1 195/10 202/2
beyond [2] 39/22
120/8
bidding [4] 93/1
big [7] 11/19 117/9
171/8 182/14 187/25
202/16 202/18
bigger [1] 194/18
bill [2] 11/9 191/20
der [1] 24/22
ders [1] 24/15
Birmingham [1]
152/6
bit [14] 10/10 94/6
121/21 131/22 135/10
140/18 141/24 145/14
146/7 151/22 153/17
161/13 194/23 197/11
bits [1] 13/6
black [1] 54/4
blame [1] 117/17
blasted [1] 164/17
block [1] 197/19
blown [1] 91/3
Board [11] 89/22
90/9 90/16 93/2
159/11 171/14 171/15}
171/17 171/21 171/25}
195/12
Board/Chairman/CE
O[1] 93/2
body [1] 96/1
body’ [1] 89/21
Bogerd [7] 57/5 89/6
94/13 96/5 99/9 172/2
203/9
bolster [1] 140/10
bolt [3] 197/3 197/9
197/21
bolt-on [1] 197/21
bolt-ons [2] 197/3
197/9
bolted [1] 196/20
bolted-on [1] 196/20
Bond [2] 92/12
203/23
Bonds [1] 143/5
bonuses [2] 95/12
99/3
bookkeeping [6]
195/20 195/25 196/10)
196/18 197/10 197/20}
books [6] 181/25
182/17 185/4 186/22
188/2 188/3
both [17] 11/22 16/23
28/3 41/23 50/11
69/23 90/11 105/23
108/11 108/17 153/2
164/7 166/12 177/11
179/15 185/6 196/3
bothered [1] 193/13
bottom [21] 1/23 7/8
27/3 32/4 32/23 33/5
33/24 34/2 34/18 44/3)
44/25 45/4 76/23
76/23 95/18 95/24
105/3 125/2 155/6
185/16 193/16
bottomed [2] 128/22
128/24
bound [2] 24/14 25/7
Bourke [2] 41/25
172/2
box [1] 54/4
boys [1] 165/17
brackets [1] 16/19
Bracknell [9] 65/16
65/18 66/23 67/6
67/10 67/14 68/16
118/4 118/25
bragging [1] 179/1
branch [28] 30/20
37/2 65/22 65/25 66/4
67/11 69/2 69/7 69/21
70/15 71/6 71/14
71/21 77/16 77/16
97/3 97/10 98/13
101/25 104/3 114/24
145/19 181/9 181/25
184/3 184/14 188/1
196/1
branch's [1] 188/3
branches [6] 20/17
68/25 93/18 131/7
185/18 189/10
brand [6] 47/5 86/16
86/18 86/20 88/15
93/4
branded [1] 32/16
Brander [9] 33/2 33/3)
33/14 33/25 36/13
38/12 40/10 47/23
116/10
brass [2] 115/3
137/10
breach [1] 49/25
breached [2] 91/10
91/10
break [11] 48/8 50/19)
50/19 50/23 83/7
83/12 114/24 154/14
154/19 154/23 157/4
breakdown [1]
101/21
Breaking [1] 23/10
breaks [1] 116/17
Bridgen [1] 138/5
brief [2] 134/3 184/10
briefing [4] 64/10
146/11 157/5 167/18
briefly [3] 176/13
176/13 177/20
bring [4] 90/18
142/19 173/1 192/5
bringing [2] 140/15
140/17
British [1] 2/20
broad [5] 3/18 15/13
15/14 126/5 126/7
broader [2] 124/5
157/24
broadly [3] 112/3
140/25 141/10
broken [1] 61/2
brought [7] 14/24
39/17 55/9 132/19
139/6 145/11 191/17
bug [10] 6/7 54/14
54/14 55/19 55/20
64/4 108/6 144/8
144/18 144/19
bugs [15] 9/1 17/1
55/2 55/16 65/19 72/5
108/1 130/12 130/19
130/20 131/8 131/11
131/14 143/13 144/16)
bullet [1] 6/4
bullies [1] 174/2
burden [2] 149/17
183/2
bureau [1] 58/3
business [16] 4/16
4/21 77/3 86/7 86/10
87/3 118/14 149/15
150/22 179/22 179/24I
187/5 187/8 187/15
187/20 188/7
businesses [3] 185/8I
186/16 187/22
but [192] 5/8 7/20
9/10 9/19 10/10 11/8
11/9 11/20 13/2 13/7
(67) becoming... - but
B
c
but... [182] 13/17
16/1 17/11 19/8 20/21
22/18 22/21 23/18
26/16 26/18 27/8 28/8
32/16 32/19 37/16
38/11 44/10 47/10
51/7 52/2 52/8 55/5
61/4 61/25 63/2 63/11
65/5 65/7 69/4 69/21
70/11 70/19 72/9 73/6
74/5 74/18 74/21
75/14 76/2 76/6 77/17
78/14 78/19 84/6
84/14 85/15 86/3
86/25 87/14 87/21
89/6 90/15 91/7 91/20
92/5 92/8 97/3 97/10
97/13 97/25 99/15
99/21 100/11 100/22
101/15 103/20 107/17;
108/12 116/7 117/11
117/47 118/10 118/16}
119/14 120/15 121/9
122/17 123/4 124/7
125/6 125/9 125/17
126/3 126/5 126/6
128/12 128/21 129/15]
130/20 131/13 131/14]
131/20 131/25 132/8
133/6 134/7 134/17
135/10 136/4 136/7
136/15 136/23 138/11
138/17 141/24 142/15]
147/10 147/17 150/18
151/14 153/11 153/16}
153/17 156/16 156/24
157/6 157/16 158/10
158/16 158/19 158/21
160/23 161/8 162/11
164/9 164/18 165/2
165/13 165/17 165/22}
166/7 166/12 167/9
167/24 168/2 169/14
169/22 170/24 171/10}
171/12 17216 172/15
172/15 172/19 173/10}
173/17 174/2 174/12
175/1 175/22 176/24
177/16 179/16 180/1
181/19 181/24 183/5
186/4 186/8 186/22
187/15 190/2 190/11
192/21 194/15 194/17]
195/15 195/21 196/5
196/16 197/3 197/12
197/24 198/2 199/15
199/20 200/4 200/9
201/8 202/10 202/18
202/18
button [1] 196/11
buy [1] 181/25
cabal [1] 172/17
cabinet [1] 25/13
calculation [1] 85/24
call [20] 1/5 32/17
33/17 76/8 79/5 79/7
81/8 107/12 107/25
109/6 112/21 130/1
136/15 141/2 170/11
173/11 175/11 192/14)
199/15 203/7
called [11] 23/18
26/13 29/19 33/3
56/15 64/1 124/3
124/10 128/15 134/11
201/11
Callendar [1] 144/18
calling [1] 201/25
callously [1] 190/2
calls [3] 89/4 89/4
175/18
came [20] 12/15
24/23 29/4 50/13
64/14 64/20 64/24
85/7 108/1 116/2
128/15 137/14 145/14)
153/17 165/22 167/25)
168/13 170/12 199/6
200/9
Camelot [2] 185/3
190/4
Cameron [10] 102/9
102/23 102/24 103/16)
130/18 131/17 131/17,
195/6 195/10 195/13
can [153] 1/3 1/4
1/11 1/17 1/22 2/9
2/18 4/13 4/25 6/21
8/13 10/15 10/15
12/12 14/21 14/23
16/10 18/17 18/18
22/19 26/5 26/24
26/25 28/22 30/3
31/12 32/9 32/11
32/12 32/21 33/16
33/23 34/2 34/20
35/19 35/23 35/24
36/8 38/23 41/20 44/1
44/3 44/8 48/8 48/22
50/19 50/25 51/3
52/21 56/4 59/23 60/8)
60/22 61/8 63/20
63/22 63/25 64/13
64/20 65/10 65/11
68/6 68/13 71/8 75/2
75/22 76/17 76/19
79/5 79/13 80/21 81/7,
81/11 82/11 83/7
83/14 85/3 87/4 88/1
89/12 91/2 92/2 94/3
94/9 94/18 94/23
95/20 96/20 97/6
97/19 101/16 102/16
103/3 103/5 103/12
104/23 105/3 108/1
109/4 109/10 109/15
110/6 110/13 111/22
114/7 118/25 122/19
122/21 123/19 123/20
125/19 129/25 130/3
132/2 132/2 132/5
134/20 138/19 146/7
146/16 147/4 151/16
154/25 155/1 155/3
156/12 160/7 161/14
162/1 162/7 162/17
165/23 171/2 173/5
173/13 174/19 175/25)
177/21 180/9 180/11
183/11 186/7 186/11
188/15 191/18 192/9
194/22 194/22 194/23
194/25 195/18 197/12)
200/21
can't [20] 22/18
23/16 23/22 23/24
25/8 28/19 49/1 55/3
65/6 73/7 76/2 78/17
87/14 119/13 119/15
146/14 161/8 164/9
176/3 197/18
canary [1] 97/23
candidates [1] 139/1
cannot [1] 96/13
capability [6] 69/1
70/1 70/6 70/24 71/12
80/7
capacity [1] 154/5
Capital [3] 111/15
137/5 137/6
car [1] 180/2
career [2] 3/2 110/20
careful [2] 42/20
84/21
carefully [3] 5/23
106/20 162/12
carried [8] 6/11 8/22
8/24 37/4 99/5 137/4
160/6 190/18
carries [1] 98/24
carry [7] 98/20
114/19 125/14 130/22]
132/20 133/3 183/1
carrying [2] 178/21
202/1
Cartwright [7] 105/5
156/1 158/25 159/4
160/15 161/4 203/22
case [67] 19/10
20/10 21/2 23/22
26/14 29/8 29/21 30/4
30/8 30/16 31/20
32/20 33/12 35/2
35/11 35/16 35/20
35/21 38/21 39/1 39/9
39/12 39/15 40/6 40/9
46/12 52/10 52/18
54/11 56/5 56/8 72/22
82/4 88/22 93/3 106/5I
106/8 106/13 118/12
118/22 128/16 136/16
136/17 141/17 144/23
145/3 145/14 145/24
147/23 148/10 150/3
156/14 156/22 165/3
169/10 170/17 170/25
173/7 173/8 179/16
180/4 183/4 188/7
196/5 198/11 202/13
203/17
cases [68] 3/10 4/10
4/10 5/13 5/20 5/22
9/9 9/22 14/7 14/9
14/9 14/13 14/15
14/19 15/19 22/8
31/22 35/9 35/10
43/17 45/3 51/25
52/15 56/3 56/11
59/16 60/10 60/13
61/17 87/16 98/8
116/12 127/4 127/24
128/1 128/7 128/10
128/13 128/19 129/2
130/20 131/20 138/20
140/19 141/12 141/18}
141/22 142/15 145/6
148/1 148/1 149/20
150/6 155/17 155/23
157/15 160/1 160/13
162/3 162/25 164/4
169/9 169/14 170/6
173/21 191/13 191/17,
203/11
cash [4] 34/6 36/22
196/2 196/3
cashpoints [1] 197/5
Castleton [4] 56/8
145/3 145/14 169/9
Catch [1] 140/18
categories [2] 56/12
145/8
caught [2] 125/1
159/16
cause [10] 9/11
13/22 16/6 117/5
149/3 149/16 161/3
181/12 181/14 184/1
caused [9] 6/8 16/4
17/18 30/20 115/25
143/15 143/15 198/1
203/3
causes [1] 156/15
causing [1] 85/2
caveats [3] 147/16
192/14 192/19
CCRC [5] 3/11
122/16 151/19 152/2
152/6
CD1 [3] 57/19 57/20
170/11
ceased [1] 200/23
centimetre [1]
183/17
central [8] 21/9 54/7
142/2 160/5 160/6
160/7 160/8 172/6
centrally [2] 181/18
182/5
centre [1] 103/15
CEO [3] 93/2 132/20
171/25
certain [5] 41/1 59/6
85/10 85/14 170/2
certainly [40] 9/2
13/14 13/23 15/15
16/5 18/6 23/17 24/6
32/19 48/4 49/22
50/20 53/11 54/10
54/18 55/6 58/23
62/10 63/16 72/8 73/5
73/15 75/18 80/19
89/3 92/24 103/20
108/6 114/2 121/11
123/4 125/6 129/22
136/22 141/7 164/18
169/20 192/8 201/5
201/22
certainty [1] 190/16
certificate [2] 23/9
26/10
certified [1] 4/5
cetera [3] 5/24 27/10
32/1
CFO [1] 111/11
chain [2] 99/4 102/13
Chair [1] 198/21
Chairman [8] 89/23
90/1 90/13 93/2
104/21 111/10 132/20}
202/3
challenge [1] 121/2
challenged [2] 63/18
88/12
chameleon [1]
174/12
chance [2] 192/11
197/24
change [3] 2/12
56/23 145/16
changed [6] 13/12
46/24 47/4 53/10
107/1 190/23
changes [2] 121/10
133/19
changing [2] 8/8
131/14
charge [11] 37/15
37/18 37/21 37/22
37/23 38/3 38/7 38/13}
50/7 66/9 78/21
charged [3] 34/13
34/15 48/12
charges [1] 37/20
charging [1] 45/9
Charles [4] 99/7
(68) but... - Charles
Cc
Charles... [3] 99/14
100/13 100/16
chartered [3] 2/22
2/25 110/14
chasing [2] 22/9
161/5
cheap [2] 11/19
136/21
check [1] 8/24
checked [2] 28/2
120/25
checking [1] 175/14
cheque [2] 120/4
120/5
cheque-clearing [1]
120/4
cheque-processing
[1] 120/5
cheques [1] 120/2
Chesterfield [1]
195/8
chief [4] 92/5 116/19
191/18 195/5
choice [1] 135/18
chopped [1] 195/11
chosen [2] 18/14
167/11
Chris [9] 41/25 84/21
85/7 94/13 103/14
139/9 152/22 172/1
172/7
chuntering [1]
126/20
cigarette [1] 85/24
circumstances [5]
23/25 35/14 85/3
91/11 96/25
circumvents [1]
178/17
Citibank [6] 111/7
137/5 137/6 137/8
185/11 185/13
civil [7] 4/9 21/20
112/15 145/11 145/13
149/12 156/21
civilly [4] 156/15
claim [2] 30/19
197/19
claimed [4] 17/5
17/17 42/22 155/24
claims [1] 85/25
clarification [1]
180/16
clarify [3] 44/8
102/16 131/4
clarity [1] 120/25
Clarke [10] 23/7
23/19 26/12 105/4
106/13 160/21 160/24
168/6 168/15 170/1
Clarke's [1] 104/22
classes [1] 53/21
clause [2] 149/10
178/16
clause 12 [1] 149/10
clean [1] 191/20
clear [45] 12/2 17/24
17/25 18/16 32/18
37/12 38/20 43/19
72/17 74/19 74/21
75/14 80/6 86/14 88/9
92/9 92/14 92/18
101/7 102/2 112/19
114/6 116/2 116/13
121/1 122/14 123/3
123/14 130/16 130/17)
133/7 133/12 134/16
135/4 137/23 157/10
163/22 163/23 166/20)
166/24 176/6 180/21
185/8 186/4 202/8
cleared [2] 185/11
193/11
clearer [1] 129/7
clearing [2] 120/4
186/5
clearly [8] 18/7 75/4
89/8 113/13 123/2
125/5 128/2 201/10
clever [1] 178/24
client [5] 92/12
118/15 138/13 188/18
193/2
client's [1] 92/21
clients [7] 12/16 95/6
97/4 97/11 185/1
186/7 188/24
clip [1] 25/3
clock [2] 154/17
181/14
clockwork [1] 193/1
close [2] 18/20
150/17
closed [2] 5/12 41/5
closest [1] 19/11
closure [2] 150/13
181/3
Co [1] 202/14
coalface [1] 187/20
coalmine [1] 97/24
coarse [1] 157/7
code [17] 6/16 6/18
7/13 7/16 7/20 7/24
8/5 8/11 9/1 9/20 9/25
10/5 10/9 15/19 22/12
50/1 133/3
code-based [2] 9/25
10/5
coding [1] 132/23
coincided [1] 161/8
colleague [2] 152/21
156/8
colleagues [5] 92/8
121/7 122/13 134/7
189/2
collecting [1] 66/4
colloquially [1] 124/1
colluding [1] 172/17
Colquhoun [2] 99/8
100/14
column [1] 31/19
combination [1] 93/2
combined [1] 178/1
combining [1]
162/11
come [30] 5/1 10/3
10/15 11/13 12/12
17/11 18/17 23/25
26/24 28/22 65/10
71/8 79/22 99/11
117/21 124/2 132/2
138/19 143/8 157/17
158/2 159/23 165/23
166/12 167/25 173/23
173/24 178/5 191/13
196/7
comes [2] 84/9 135/7
coming [5] 81/17
91/5 139/1 192/21
202/15
comma [1] 120/23
comment [2] 41/13
91/16
commented [1]
41/14
comments [2] 87/22
151/1
commercial [7]
21/20 50/5 78/1 78/14
96/10 98/1 98/22
commercially [1]
96/24
commission [2] 3/11
12/3
commissioned [2]
56/2 192/10
commissioning [1]
11/25
commitment [1]
46/25
committed [2] 142/8
149/9
Committee [2] 89/6
111/11
common [1] 31/15
communicate [1]
171/25
communicated [1]
136/8
communicating [2]
120/7 126/18
communication [4]
18/16 52/24 52/25
161/2
companies [6] 3/19
91/12 98/2 117/9
146/4 173/19
company [8] 3/23
5/23 5/25 82/16
110/21 111/4 143/17
178/10
company-held [1]
5/23
comparative [1]
131/18
comparatively [1]
51/13
compared [1] 11/19
comparison [1]
200/23
compelling [1]
156/25
compendium [3]
142/18 143/20 145/24}
compensation [4]
85/23 86/3 201/13
201/15
competency [1]
169/23
competent [3] 11/21
155/22 160/13
Complaint [2] 30/5
127/1
complaints [4] 31/1
44/25 45/4 142/1
complete [5] 37/9
41/4 43/15 106/11
170/5
completely [7]
115/14 121/1 125/17
141/23 165/18 202/8
203/25
completeness [1]
104/18
complex [1] 187/13
complicated [2] 7/14
185/23
comply [2] 50/2
88/19
component [1]
188/18
comprised [3] 12/16
137/16 170/18
computer [7] 4/3 4/5
38/9 78/10 143/2
166/8 166/19
computers [1] 122/8
conceding [1] 123/14
concentrate [1] 94/9
concern [9] 13/18
13/19 46/9 59/3 74/17}
133/8 133/12 158/13
181/15
concerned [33] 9/19
10/21 13/25 17/18
22/1 40/20 43/1 48/7
49/17 49/24 49/25
54/4 62/19 62/23 74/2,
74/5 85/11 86/9 86/15)
91/4 98/11 103/5
125/15 132/22 132/24}
137/20 146/6 190/3
190/4 190/9 198/25
199/2 199/13
concerning [8] 53/22
54/8 112/12 144/6
144/16 166/23 187/8
190/14
concerns [19] 15/2
15/6 45/1 50/3 60/21
61/5 61/22 61/25 62/9I
79/17 107/13 112/7
1412/7 123/2 125/5
152/14 152/18 169/17)
180/16
concessions [1]
203/15
conclude [1] 181/20
concludes [1] 108/15)
concluding [1] 171/2
conclusion [12]
17/13 30/16 30/18
31/3 43/21 84/19
128/3 128/8 128/18
129/1 130/3 150/5
conclusions [9] 15/4
18/4 38/10 113/20
117/18 128/4 135/6
136/13 168/20
conduct [15] 5/11
5/18 22/13 46/13 50/1
58/15 91/21 112/3
124/6 137/9 156/24
163/7 167/13 169/17
200/15
conducted [7] 30/14
34/1 53/13 58/6 73/4
170/3 195/19
conducting [6] 88/22
90/6 114/4 150/24
178/24 179/19
conducts [1] 148/15
conduit [4] 134/19
138/18 172/1 172/4
conduits [2] 134/11
172/10
conference [4] 75/24
76/7 89/4 107/2
confidence [1] 41/4
confident [1] 155/16
confidential [1] 14/1
confidentiality [7]
12/25 13/8 13/24
91/10 139/15 139/25
177/17
confirm [4] 60/8
60/24 157/12 162/1
confirmation [1]
67/18
confirmed [4] 66/6
68/25 118/24 169/12
confirming [2] 40/25
7219
conflict [7] 73/14
73/15 74/24 75/20
118/1 118/3 118/15
confusing [2] 126/4
188/8
(69) Charles... - confusing
Cc
confusion [2] 16/6
125/10
connect [1] 65/25
connected [1] 97/17
connecting [1] 69/20
connection [1] 119/8
conscious [1] 63/12
consensus [2]
150/12 150/18
consent [3] 17/20
41/7 65/23
consequence [1]
39/25
consequences [8]
47/1 83/21 84/8 85/17)
85/21 115/24 151/1
190/20
consider [9] 15/1
15/5 15/12 37/12
42/24 59/12 59/15
99/24 158/17
considerable [2]
129/14 136/6
consideration [2]
15/8 124/6
considered [12]
10/10 10/11 16/14
35/10 40/23 43/9
43/11 58/16 62/11
95/21 113/9 188/9
considering [4]
87/10 87/12 116/11
170/6
considers [1] 90/25
consistent [3] 31/22
40/23 84/7
consistently [3] 57/7
88/4 88/25
conspiring [1]
172/17
constant [2] 63/15
119/4
constantly [2] 8/8
47/7
constituencies [1]
14/18
constituents [6]
112/8 127/11 132/25
158/13 160/1 160/4
constrained [1]
165/10
constructive [1]
78/12
consultant [1] 3/21
contact [14] 21/24
22/2 67/24 76/11
76/14 82/11 84/2
86/13 89/3 107/11
108/12 122/11 134/8
166/13
contain [1] 174/7
contained [3] 44/19
45/8 203/13
contemplating [1]
115/12
contemporaneously
[2] 167/5 199/9
contended [1]
133/22
contention [1] 119/8
contents [6] 2/15
35/1 35/16 41/4 110/3)
110/10
context [13] 15/17
34/15 49/22 53/1
77/23 79/11 85/6
88/24 99/17 100/24
131/15 175/4 196/17
contextually [1]
186/20
continue [6] 42/18
50/25 53/9 66/17
79/20 99/4
continued [5] 75/22
85/2 88/17 127/5
184/6
continues [4] 9/7
39/24 100/8 174/4
continuing [1] 59/17
contract [16] 12/17
12/21 13/2 13/5 13/7
13/9 68/19 92/21
119/10 119/16 136/2
137/16 149/11 149/17)
177/8 177/16
contract/introduction
s [1] 92/21
contracted [2] 112/2
171/16
contractor [2] 3/21
90/22
contractually [1]
137/21
contradictory [1]
131/3
contrary [1] 72/16
contributed [1] 180/3)
contributions [1]
90/8
control [6] 11/10
21/2 57/23 113/10
114/17 114/19
controls [1] 30/23
conversation [5]
75/5 85/13 174/4
174/19 176/6
conversations [5]
21/17 48/23 72/22
120/7 175/17
converted [2] 58/3
77/25
convey [1] 106/15
conveyed [1] 136/18
conveying [1] 134/13
convicted [1] 201/19
conviction [11] 38/1
60/15 61/6 61/19
88/10 149/7 162/5
162/9 163/2 164/2
165/5
convictions [10]
60/25 66/8 84/6 87/10
87/13 87/16 87/24
88/7 89/10 202/9
convincingly [2]
136/18 150/15
cooperating [1]
115/17
cooperation [2]
112/20 115/5
copied [8] 8/18 41/24
51/6 60/3 94/12
100/14 134/24 151/21
copies [1] 19/22
copy [34] 19/21 23/3
23/5 23/13 23/14
23/23 24/1 24/22
25/11 25/17 25/20
27/9 27/10 27/15 32/5)
32/16 35/20 40/1
40/18 40/24 42/12
44/4 47/23 58/1
104/24 105/25 119/9
152/21 153/5 153/8
153/13 153/18 168/9
198/4
copying [2] 152/24
153/10
core [1] 199/3
corporate [2] 141/9
173/24
corporation [2] 114/7I
178/9
correct [43] 3/1 3/5
3/6 3/9 4/4 4/6 4/12
6/9 6/20 7/2 7/6 8/3
26/23 28/12 32/6
32/25 34/11 34/24
34/25 36/6 36/14 39/2
40/7 40/11 42/8 43/24
45/12 45/14 45/21
46/2 46/6 62/5 73/2
90/5 96/17 106/3
107/18 112/17 165/25)
166/3 168/10 177/15
180/22
corrected [1] 121/11
correction [2] 109/16
110/2
correctly [1] 187/4
correspondence [8]
46/15 46/16 46/17
47/9 47/18 68/4
145/17 152/2
corroboration [1]
75/22
corruption [1] 202/10]
cost [4] 7/13 78/15
149/22 159/20
costs [1] 7/22
costs' [1] 93/4
cough [1] 191/16
could [49] 17/22 18/2
19/9 19/15 20/19
24/16 28/4 30/23
48/12 58/4 58/9 62/7
63/1 65/25 67/17
67/21 70/15 73/11
75/8 79/10 81/17
100/1 100/19 101/24
103/19 104/2 112/12
112/15 113/10 113/10}
114/23 118/10 127/24}
132/10 138/17 142/5
156/17 158/9 159/5
164/1 166/21 167/2
167/6 167/22 181/24
182/7 182/13 184/15
195/16
couldn't [7] 91/7
106/17 118/1 163/17
182/11 182/12 182/15)
counsel [8] 15/23
104/21 152/24 154/3
154/6 155/24 164/11
175/22
counter [2] 31/6
76/19
counting [1] 128/11
countries [1] 173/20
country [3] 8/10
22/10 122/10
country's [1] 3/8
couple [4] 35/24
51/25 161/19 177/1
courage [2] 179/4
179/8
course [31] 2/1 9/2
11/20 13/12 14/6
15/17 17/7 27/18 29/1
59/25 83/9 91/23
92/18 104/6 105/12
112/10 114/25 122/12}
122/15 128/12 129/20}
130/11 133/11 136/2
137/13 164/19 172/7
183/14 184/8 186/18
202/19
court [9] 5/21 38/8
56/3 142/23 166/22
167/4 168/14 169/6
193/24
courts [1] 167/22
cover [5] 5/22 46/8
102/5 158/4 186/10
covered [1] 127/6
covertly [1] 175/18
Coyne [2] 56/5
177/24
Coyne's [1] 144/22
CPs [1] 175/23
CQRs [1] 202/13
crafted [1] 162/12
create [2] 29/21
43/22
creating [1] 95/3
credibility [1] 186/12
credible [1] 156/19
credibly [1] 166/12
credit [4] 95/10 99/2
121/14 183/4
credited [1] 189/6
credits [2] 189/5
189/14
creep [1] 125/10
Crichton [31] 4/22
5/3 8/17 15/22 21/12
21/18 48/3 48/18
48/23 53/2 57/5 58/23
81/10 92/19 115/19
127/21 133/17 134/24)
136/24 145/22 146/1
152/10 155/13 156/5
157/5 158/24 160/14
163/6 166/11 176/20
199/7
Crichton's [5] 18/25
47/2 50/3 55/10
165/25
Crighton [1] 112/23
criminal [48] 3/10
4/10 21/13 21/20
21/22 35/6 39/16
41/16 49/20 49/21
50/6 50/7 58/16 62/4
62/6 62/11 62/23
63/14 66/7 71/22
71/22 84/6 84/11
84/14 87/15 87/16
87/24 88/7 88/10
88/19 89/9 91/22
105/19 106/18 112/15}
122/17 143/22 145/7
149/10 155/19 155/23)
155/25 157/13 160/13}
163/11 169/14 169/18}
170/3
criminally [1] 156/16
crisp [1] 167/7
critical [2] 53/12
200/4
criticise [1] 194/15
criticism [2] 16/1
79/2
Crowe [8] 94/12 96/5
99/7 99/8 100/13
100/14 152/24 172/1
Crown [3] 22/13 50/1
59/13
CRR [8] 29/22 40/3
43/13 43/13 43/19
49/10 50/15 120/19
CRRs [3] 41/12
118/11 121/5
cruel [1] 185/22
crystal [2] 133/7
133/11
culminates [1] 30/15
(60) confusion - culminates
Cc
culture [1] 150/23
current [2] 69/4
7415
currently [1] 191/10
curve [1] 140/17
custodial [1] 38/1
customer [2] 186/6
186/8
customers [4]
141/11 142/11 188/23}
190/1
cut [2] 133/18 139/22
D
daft [4] 138/11
163/20 163/21 178/21
damn [1] 185/16
danger [3] 98/25
129/24 192/23
data [23] 66/9 71/13
77/21 77125 78/5 78/6
78/8 78/8 78/8 78/10
78/15 78/21 100/23
101/3 101/17 115/21
417/17 128/1 143/15
149/22 149/24 159/18)
194/7
databases [1] 69/22
date [26] 36/14 49/1
60/18 60/24 64/23
65/5 79/10 94/10
95/23 95/25 100/13
102/23 103/22 115/7
133/6 147/11 148/5
168/18 173/10 174/18
174/25 176/1 176/3
176/4 190/23 190/24
dated [18] 1/16 4/21
5/4 26/1 33/13 35/23
36/11 39/10 39/13
41/22 68/10 81/11
87/6 102/9 109/15
110/7 119/17 139/17
dates [2] 28/17
175/25
Davies [2] 81/9 86/13
day [15] 8/16 14/3
14/4 21/24 21/24 22/2)
22/2 41/21 47/6 61/9
78/4 98/23 115/3
182/16 204/20
days [9] 22/25 27/6
41/18 57/19 76/20
98/5 98/21 136/1
179/22
deal [11] 72/10 74/19
80/17 122/6 135/6
136/13 141/5 157/11
176/12 176/13 185/13}
dealing [21] 13/7
22/7 22/8 43/3 48/2
57/4 65/18 75/19
82/18 96/21 106/20
114/8 118/15 121/24
122/23 172/13 175/10)
175/19 185/17 187/19)
201/23
dealings [3] 16/12
78/24 80/21
dealt [7] 48/10 74/8
85/9 106/23 163/9
180/19 182/16
debate [2] 136/6
201/18
debts [1] 187/22
December [1] 171/19
decency [2] 157/17
158/6
decentralised [2]
19/25 21/4
decided [3] 5/11 67/3
155/12
decision [3] 89/22
137/14 138/11
decisions [2] 53/14
86/10
dedication [1] 179/8
deep [4] 8/25 9/9
9/13 133/3
deeper [1] 190/17
deeply [4] 9/1 12/15
137/15 190/14
deeply-embedded [1]
9/1
defect [1] 131/12
defects [12] 17/1
60/14 61/3 65/19 72/5)
143/13 162/4 162/8
163/24 164/1 164/2
165/4
defence [7] 6/1 37/3
49/21 56/19 155/20
170/16 170/20
defensive [1] 82/21
deficiencies [4]
53/23 54/9 63/10
144/6
deficiency [1] 71/16
define [2] 16/9
163/25
defined [1] 124/9
definitely [5] 28/7
115/22 124/5 125/17
130/21
definition [1] 16/5
degree [2] 85/14
121/6
delay [3] 117/5 186/5
186/7
deleted [1] 43/23
deliberate [1] 14/12
deliberately [3] 34/7
36/23 44/20
delighted [1] 2/10
deliver [1] 142/5
demand [1] 38/8
demanded [2]
171/11 171/14
demonstrated [3]
11/22 31/8 67/11
demonstration [1]
77/15
den [7] 57/5 89/6
94/12 96/5 99/8 172/2
203/9
denied [3] 72/25
149/22 198/24
denying [2] 113/16
118/5
department [30]
18/23 19/14 19/23
20/4 20/6 20/13 20/19
21/1 21/25 22/17 24/2
24/11 25/14 29/5
33/11 33/21 47/12
48/2 49/1 49/14 50/6
53/7 57/22 147/1
147/2 147/6 147/19
151/12 152/15 195/9
departments [1]
117/11
departure [1] 201/3
depending [1] 187/5
depth [2] 15/19 31/8
describe [7] 23/14
24/13 82/22 107/17
124/12 132/4 181/1
described [16] 14/25
19/17 32/5 37/8 44/10
71/6 75/7 77/10 97/1
106/16 115/14 143/14]
168/2 181/6 194/10
197/7
describes [1] 87/8
describing [4] 4/23
11/2 68/20 70/25
description [4] 31/21
141/6 176/1 187/16
desire [5] 52/14 84/8
85/16 133/3 149/5
desires [1] 134/18
desk [3] 25/16 25/18
194/10
desk-based [1]
194/10
desktop [2] 69/18
70/23
despite [3] 89/19
113/1 150/9
detail [18] 16/15
17/11 29/6 37/10
42/23 69/14 69/24
70/11 70/21 75/2
75/18 85/5 102/4
111/22 121/25 128/14
194/13 195/16
detailed [7] 1/15
16/13 37/4 101/21
103/25 108/18 117/2
details [3] 94/18
94/20 99/20
detect [2] 156/17
195/17
determined [3] 86/17
118/14 127/13
develop [1] 174/10
development [1]
126/25
devil [2] 161/7
184/13
ionary [1] 16/2
did [156] 3/18 3/19
10/3 10/25 11/15
12/10 13/5 13/6 13/22)
14/9 17/2 17/24 18/14}
19/8 21/2 21/16 22/2
22/4 22/17 23/25
26/11 28/8 29/17 35/5)
35/14 35/19 46/20
48/13 48/19 50/3
52/14 52/19 53/8
53/20 54/7 54/13
54/16 54/21 54/24
55/25 56/10 56/17
56/21 56/22 57/1 57/2
58/19 58/22 59/12
59/17 66/3 68/3 70/6
70/23 71/20 71/25
72/4 72/10 72/11
72/13 73/3 73/22
74/22 74/24 75/9
75/17 78/24 79/1 80/8)
81/18 81/21 81/22
86/12 86/24 87/11
88/24 90/13 92/11
95/2 105/8 106/14
107/10 108/5 108/9
113/23 114/3 115/6
120/18 120/21 121/4
121/15 122/1 122/17
125/14 126/16 127/19}
129/24 130/19 130/24I
131/24 135/20 135/23}
136/9 136/19 139/12
139/23 140/3 140/24
144/4 144/14 144/22
145/1 145/5 145/15
145/23 146/21 148/21
150/6 151/14 152/2
157/2 157/8 160/10
164/6 166/14 166/18
166/20 167/1 168/11
169/2 169/5 169/10
169/11 170/9 170/19
171/16 171/21 175/16}
176/20 177/17 179/20}
184/13 192/24 192/24
193/13 193/15 195/19}
195/22 196/14 197/6
199/10 199/11 200/2
200/8 200/22 203/16
didn't [62] 2/3 9/24
11/9 12/2 12/7 14/18
22/6 22/15 27/14 31/8
Di
35/18 47/5 48/5 53/10
53/10 54/2 54/5 54/18}
59/9 59/15 59/19
62/19 62/21 72/9 80/9
82/16 83/1 83/2 87/15
88/19 90/3 91/25
98/19 105/17 105/22
107/11 107/17 126/21
129/13 134/13 158/11
158/18 160/16 161/9
164/14 165/12 167/15)
167/23 167/25 168/4
168/14 169/19 171/22)
176/23 190/2 191/11
193/9 193/9 193/17
195/21 202/16 202/18}
die [1] 80/13
difference [3] 121/21
185/1 185/17
different [17] 33/6
69/8 69/16 117/10
121/18 129/8 132/1
150/10 157/23 160/20}
163/9 178/11 1814/1
185/4 187/24 188/6
188/10
differently [3] 89/15
135/19 171/5
difficult [8] 35/7 47/6
74/18 115/7 117/15
122/6 133/4 167/6
difficulties [6] 21/1
201/21 201/22 202/24I
202/25 203/3
difficulty [3] 15/21
120/6 138/25
dig [5] 8/25 79/20
128/16 194/13 194/13}
digging [1] 9/13
dined [1] 186/19
dining [1] 180/2
direct [4] 11/9 69/17
89/3 90/1
directly [6] 66/3 66/4
67/24 72/25 121/15
155/13
director [3] 103/17
111/15 111/19
directors [3] 89/24
90/2 195/12
disagree [1] 88/12
disagreed [1] 125/18
disallowed [1]
113/11
disciplinary [1]
112/16
disclose [5] 72/4
74/3 74/10 108/5
156/17
disclosed [35] 22/24
23/8 23/17 23/21
26/16 27/5 27/14
28/15 28/16 38/18
40/6 42/10 42/12 43/5)
(61) culture - disclosed
D
disclosed... [21] 43/8
45/7 47/22 48/20
48/20 49/19 49/19
49/20 55/24 56/16
64/16 65/5 74/16
74/24 108/12 130/16
130/24 131/1 170/15
170/16 170/20
disclosing [4] 14/1
48/7 74/15 156/19
disclosure [26] 13/1
13/8 13/23 39/20
39/25 40/13 40/21
40/23 42/14 42/15
42/25 43/2 43/12
45/16 55/4 58/9 58/15
62/2 62/16 62/24
84/25 88/21 91/10
94/17 108/8 177/2
discovered [1] 37/22
discovery [1] 145/20
discredited [2]
106/17 107/8
discrepancies [1]
96/17
discrepancy [2] 9/12
31/7
discuss [3] 76/24
81/4 145/23
discussed [12] 25/24
66/22 68/24 72/9
73/20 75/18 84/4
100/17 101/13 102/8
103/13 103/14
discussing [1]
102/22
discussion [8] 16/13
52/11 78/1 99/5 100/8I
129/15 155/14 180/21
discussions [4]
54/19 71/16 77/12
155/8
disinterest [1] 149/5
dismiss [1] 203/25
displaced [1] 125/13
displaced/vaporised
[1] 125/13
disproportionate [1]
7/22
disprove [1] 189/4
dispute [2] 181/18
182/5
disregarded [1] 84/7
distance [2] 51/25
52/14
distinction [2]
166/20 166/24
divert [1] 140/16
diverted [1] 127/3
diverting [1] 16/25
divested [1] 20/3
dividends [2] 95/12
99/3
division [2] 3/3 122/3
do [93] 3/19 6/25
7/19 7/24 8/19 10/13
10/16 11/7 11/21 12/5)
13/3 13/4 16/17 17/3
17/24 22/12 24/16
24/21 25/16 28/19
33/1 33/3 51/4 53/15
57/20 59/1 62/5 69/11
70/11 70/19 71/1 71/5)
72/11 78/3 81/16
87/11 87/14 87/25
90/24 92/23 93/6 93/8)
93/24 97/2 97/9 97/12
99/15 99/19 99/20
100/23 101/16 106/8
107/23 108/3 113/10
115/16 117/13 120/11
120/21 122/2 122/12
124/19 127/5 127/6
129/6 133/4 135/2
135/19 136/19 147/3
153/23 160/14 164/22)
167/11 168/4 168/5
172/9 175/13 178/3
178/10 179/10 179/25)
181/16 182/11 182/12)
182/18 183/9 191/11
193/3 194/9 195/12
197/14 197/22
document [73] 4/22
4/25 5/5 5/6 5/7 23/7
24/13 25/7 25/19
25/24 26/3 26/6 26/14
27/16 27/17 28/6
28/13 31/21 32/7 32/9
32/12 32/16 32/22
32/24 34/21 34/23
36/16 36/18 40/2
40/17 42/9 42/12
42/16 42/19 42/20
42/24 44/4 44/9 44/18
45/7 45/11 45/19 46/4
63/21 64/1 64/4 64/6
64/9 64/12 64/16
64/24 76/4 87/6 94/3
102/21 104/25 105/2
105/8 106/14 107/17
108/9 132/15 145/21
146/18 146/20 151/24)
154/2 157/4 168/12
170/22 173/2 192/6
194/23
documentary [1]
64/21
documentation [12]
5/23 34/5 36/21 51/11
51/15 53/21 54/25
88/9 113/4 122/7
144/15 147/25
documented [1]
54/14
documenting [1]
144/8
documents [49]
24/16 25/1 25/10 28/1
28/7 28/11 31/13
31/16 32/15 36/1 36/3
36/10 37/11 40/4 41/1
41/3 43/1 43/8 46/12
46/16 47/8 47/17 48/7
54/22 55/16 56/12
56/14 56/15 68/5 89/8
106/12 108/13 112/21
115/11 121/17 125/19}
129/21 144/5 144/12
145/8 151/16 170/13
170/15 170/15 170/19}
170/20 170/24 198/8
198/10
does [21] 5/8 9/4 9/6
9/15 23/15 37/13
39/22 42/20 92/14
132/21 135/8 140/6
156/24 174/6 174/10
185/10 185/13 185/17)
185/21 194/4 194/6
doesn't [4] 47/18
149/13 174/11 196/17!
dog' [4] 92/25
doing [17] 6/15 9/20
11/10 67/7 85/23
92/23 93/1 113/11
113/23 114/3 120/1
124/2 147/5 170/22
176/25 188/12 203/22
don't [43] 10/6 10/14
11/18 12/6 15/14
16/13 20/20 50/11
53/24 54/11 54/19
59/15 62/17 70/3 72/6
76/5 87/19 101/20
101/23 102/18 105/9
110/25 135/23 138/14
138/14 153/15 157/10
158/18 160/22 161/1
163/7 164/9 168/1
173/10 176/23 176/24
177/22 183/3 184/19
184/20 187/23 193/20
197/13
done [26] 18/8 25/4
44/12 50/10 59/1
60/18 63/9 67/21
67/22 70/7 82/3 84/15)
89/15 100/1 108/8
123/23 123/25 127/13
151/13 154/8 171/5
173/17 185/21 194/19}
194/20 202/14
door [2] 146/6
161/10
doors [1] 14/12
double [12] 182/19
195/20 195/24 196/2
196/9 196/18 197/7
197/10 197/13 197/18}
197/20 197/24
double-entry [4]
195/20 197/7 197/10
197/20
double-whammy [1]
182/19
doubled [1] 196/12
doubt [5] 9/12 79/9
158/20 160/24 200/10)
doubting [2] 28/10
171/13
down [43] 5/14 6/3
7IT 8/14 8/21 10/15
10/18 12/12 18/17
23/10 26/24 28/22
30/12 31/11 32/3
33/10 33/13 44/3 44/6
60/2 61/2 65/10 68/6
71/8 79/13 83/5 92/8
94/6 101/22 121/23
128/12 130/9 132/2
134/10 138/19 154/18}
157/23 161/10 161/18
162/22 165/23 194/3
194/23
dozen [3] 47/14 58/7
116/11
Dr [4] 177/25
Dr Worden [1]
177/25
draconian [2] 90/23
192/19
draft [12] 41/12
43/13 95/21 97/5
100/6 101/12 129/22
147/14 147/15 147/21
151/8 157/3
drafted [2] 39/6
146/20
drafting [2] 118/21
120/18
drafts [2] 118/12
129/21
draw [5] 141/12
141/17 142/2 144/4
192/16
drawing [1] 9/23
drew [2] 156/7
191/12
drill [1] 69/14
driven [1] 149/5
driver [1] 186/14
driving [3] 86/10
136/24 201/25
dropped [1] 80/3
duck [4] 117/16
due [6] 30/23 133/11
137/13 185/3 185/5
191/3
dumped [1] 158/10
during [13] 18/21
67/9 115/15 116/6
117/1 118/21 130/19
147/24 155/15 182/18
186/11 189/14 200/7
dusted [4] 153/19
duties [4] 166/21
167/3 169/2 169/16
duty [5] 2/2 13/3 50/2
91/19 91/24
dysfunctional [1]
201/6
E
each [9] 30/8 32/15
34/18 56/18 72/23
96/13 117/1 117/11
149/19
earlier [13] 69/9
69/12 75/24 105/17
116/10 124/1 129/11
157/25 163/4 163/16
171/18 178/5 186/17
early [15] 49/3 51/14
52/5 52/18 84/1 85/19I
115/8 116/6 116/7
133/21 138/20 148/7
164/24 167/15 201/4
earth [2] 164/1
167/21
easily [1] 121/7
East [2] 111/12
111/16
easy [1] 96/18
educated [1] 175/2
educational [1]
165/16
effect [7] 16/22 97/20
123/11 152/19 170/1
182/19 198/25
effective [2] 58/14
142/5
effectively [2] 58/5
196/14
efficient [2] 146/4
146/11
efficiently [1] 127/25
effort [1] 80/9
efforts [1] 12/4
eg [3] 30/24 88/19
101/9
ego [1] 160/22
eight [1] 8/21
either [15] 14/19
47/23 72/14 90/6 93/3)
95/5 112/11 143/24
148/15 149/13 150/1
155/21 157/11 168/7
176/1
Electric [1] 21/19
electronic [4] 19/18
58/2 142/19 196/24
electronically [1]
170/24
element [2] 13/2 62/9)
eligible [1] 88/11
else [7] 74/6 95/13
151/4 178/9 188/1
(62) disclosed... - else
E
else... [2] 193/4
202/6
elsewhere [1] 194/9
email [34] 8/15 51/5
60/3 62/17 67/5 67/16
92/2 92/3 94/5 94/7
94/10 95/22 96/1 99/4
100/15 100/17 102/7
102/7 102/8 102/13
103/11 107/11 118/9
118/24 133/16 133/20
134/22 136/11 145/17)
151/18 152/2 153/8
161/18 173/3
emails [6] 55/1 80/5
80/19 118/7 130/17
144/16
embedded [3] 9/1
22/17 27/18
embryonic [1] 158/9
emotional [1] 75/14
empathetic [1]
203/10
emphasis [1] 186/13
emphasised [1]
133/25
employee [2] 82/10
90/20
employees [5] 66/23
67/6 87/23 137/9
153/10
employer [2] 92/11
142/16
enable [1] 37/9
enabled [2] 47/16
178/4
encountered [3]
118/13 118/16 121/25}
encountering [1]
122/1
encourage [1]
174/10
encouraged [1]
118/7
end [17] 16/8 69/22
83/8 90/14 92/3 94/18
98/23 102/2 148/6
151/12 174/22 178/2
186/23 196/20 197/21
201/5 203/3
endemic [1] 37/2
ending [3] 31/25
101/6 115/13
enemy [1] 150/22
engage [1] 152/2
engaged [5] 46/17
137/21 199/4 199/12
199/14
engagement [8]
78/12 92/3 127/9
135/3 136/3 136/7
139/20 174/6
engages [1] 178/9
engineer [5] 65/15
67/25 68/18 74/20
198/7
engineers [2] 8/2 8/3
England [4] 2/25
14/10 14/11 21/6
English [2] 14/17
16/2
enormous [1] 190/20
enough [4] 135/22
165/14 167/14 167/21
ensure [3] 60/6 98/3
161/24
ensured [2] 119/20
177/17
enter [1] 197/13
enterprise [1] 83/23
entire [3] 15/20
120/24 127/23
entirely [5] 53/4
113/9 156/19 159/4
160/20
entirety [2] 94/8
131/15
entitled [4] 78/21
129/20 154/6 202/9
entitlement [1] 78/18
entries [5] 66/9 185/6
191/16 196/19 197/19)
entry [13] 195/20
195/24 196/2 196/9
196/14 196/18 197/7
197/10 197/13 197/18)
197/20 197/24 197/25)
envisage [1] 157/8
envisaged [2] 6/10
132/11
episode [1] 164/23
equally [5] 63/11
92/14 97/13 97/25
123/3
equals [1] 76/21
equivalent [2] 90/23
149/11
era [1] 92/19
Ernst [3] 73/6 110/22
111/5
error [7] 17/17 30/21
30/22 56/15 72/8
131/12 191/4
error-free [1] 17/17
errors [7] 17/1 31/5
65/19 72/5 130/25
131/1 143/13
errors’ [2] 130/15
130/23
escape [1] 178/16
essential [1] 155/20
essentially [12] 7/1
7/25 64/10 77/10
98/25 122/6 163/14
177/7 177/20 1814/3
182/7 182/20
establish [7] 61/16
149/3 149/15 149/25
162/24 170/19 189/8
estimate [1] 186/1
et [3] 5/24 27/10 32/1
et cetera [3] 5/24
27/10 32/1
ete [3] 6/7 7/13 135/3
ethics [1] 169/23
Europe [2] 111/12
111/16
Evans [1] 139/23
evasive [1] 80/24
even [19] 12/11
18/14 37/20 68/2 82/9
87/16 93/2 127/25
128/22 130/15 130/23
133/20 146/4 149/19
182/24 186/3 189/24
191/19 193/10
event [7] 107/13
111/4 114/1 141/16
149/9 149/13 154/19
events [7] 46/11
104/6 126/24 128/16
131/19 141/5 141/10
eventually [6] 55/4
113/8 120/15 158/21
184/25 199/21
ever [20] 10/3 10/4
10/7 15/16 90/6 92/11
99/21 115/16 117/4
118/5 143/17 151/8
155/24 159/5 169/3
171/16 171/21 173/24]
191/19 194/25
every [13] 33/20
118/17 118/17 118/18}
120/22 120/22 120/22
155/23 156/14 170/22
172/18 189/5 197/25
everybody [2] 126/4
201/24
everything [12]
19/20 48/19 49/18
53/4 59/1 91/13 95/12
121/3 151/15 172/15
191/10 194/12
evidence [72] 1/14
4/9 6/1 9/20 15/4
17/22 18/2 23/6 23/19
26/12 26/13 26/15
27/16 27/23 30/18
34/6 36/22 37/1 37/15
37/22 38/13 38/17
39/5 44/20 61/5 62/8
62/24 64/22 72/1 72/2
73/15 73/24 74/11
74/25 75/20 84/11
84/13 85/7 87/2 89/5
91/5 91/19 91/20
104/25 105/11 105/18!
106/1 106/7 108/15
108/18 116/13 117/3
119/13 119/15 122/8
128/5 133/23 134/4
137/1 153/20 155/17
156/20 156/20 156/21
166/1 168/23 169/5
169/11 177/5 190/24
193/18 204/9
evidenced [2] 119/6
158/2
evident [1] 86/24
evidential [2] 62/9
122/2
evolved [2] 179/16
181/16
exacerbated [1]
196/23
exact [5] 49/1 65/5
70/22 71/5 115/7
exactly [13] 32/18
60/2 65/2 68/6 115/22
129/13 133/5 135/2
164/10 166/9 174/12
175/14 192/23
examination [2] 6/19
128/19
examined [3] 30/18
47/21 150/6
examiner [1] 4/5
Examiners [1] 4/3
examining [1] 120/22)
example [15] 22/13
29/14 53/22 54/25
56/5 56/13 71/17 81/7,
88/6 116/18 118/3
118/23 119/7 187/7
198/3
examples [2] 119/1
191/14
exasperated [1]
146/3
excellent [1] 135/2
exception [2] 177/19
178/12
exceptional [1] 96/25]
excess [1] 98/9
excessively [1]
117/10
exchange [8] 51/5
62/17 161/14 185/13
197/6 197/16 198/3
198/7
exclusively [2] 14/17
82/15
exculpatory [2]
38/17 156/19
Excuse [1] 104/9
executive [3] 30/11
89/24 90/2
executives [2] 19/8
198/20
exemption [2] 23/9
26/11
exercise [3] 114/18
135/5 173/6
exerts [1] 92/15
exhibit [2] 32/17
33/17
exist [4] 17/2 130/19
130/21 184/6
existed [3] 69/1
133/6 190/14
existence [12] 54/13
54/16 54/21 56/13
56/24 72/4 125/25
126/1 145/16 153/6
168/6 168/11
existential [4] 86/7
114/9 114/13 114/14
expanding [1] 165/11
expect [9] 106/13
141/25 142/9 142/14
150/15 183/25 185/7
185/8 185/12
expectation [7]
123/3 182/24 183/25
199/23 201/11 201/14)
202/11
expected [8] 68/21
106/11 117/4 123/9
134/9 138/21 188/4
201/13
expecting [2] 141/8
202/20
expenditure [1]
78/23
expense’ [1] 159/12
experience [7] 9/8
11/6 118/20 122/16
141/9 156/23 164/15
experienced [6] 35/8
113/15 155/19 155/22
160/13 163/11
expert [34] 4/10 56/1
62/4 62/6 62/8 63/3
63/4 71/18 72/1 74/7
82/14 82/19 105/20
106/22 115/20 157/13)
166/4 166/7 166/8
166/22 167/3 167/10
167/12 167/14 167/20}
167/24 167/25 168/1
168/3 169/2 169/6
169/13 169/15 169/16
expertise [8] 41/17
50/8 58/24 62/22 72/3}
149/24 155/25 163/15
experts [5] 58/16
62/11 84/10 84/11
84/14
explain [10] 40/22
41/8 41/10 42/23
43/20 75/2 82/11 91/2
169/16 180/25
explained [6] 76/18
84/12 146/7 158/12
164/14 184/25
explaining [3] 120/14)
120/15 184/23
(63) else... - explaining
E
explanation [4] 31/6
97/14 97/16 103/19
explanations [1] 95/8}
expletive [2] 146/13
159/14
explicitly [1] 53/24
exploration [1] 29/15
explore [4] 33/7 72/9
111/23 130/2
explored [1] 138/12
express [1] 52/14
expressed [8] 18/7
51/24 116/21 123/2
125/5 125/9 133/2
180/17
expressing [2] 81/7
174/9
extended [1] 69/22
Extensible [1] 78/9
extensive [1] 68/3
extent [4] 39/22 59/6
78/25 85/10
external [6] 48/3
85/20 89/22 93/1
110/20 149/24
extra [1] 196/7
extract [1] 48/11
extracts [1] 40/9
extraordinarily [1]
159/19
extraordinary [1]
135/16
extreme [3] 120/24
142/7 201/7
eye [4] 179/18
F
face [11] 77/18 77/18
78/11 120/13 122/11
122/11 134/8 134/8
156/2 156/2 160/3
faced [2] 29/15
181/23
faces [1] 80/2
facetious [1] 163/19
facilitate [1] 70/10
facilitated [1] 106/24
facility [8] 53/8 56/24
66/6 71/21 77/15
77/17 90/20 145/17
facing [1] 91/20
fact [37] 7/14 8/6 8/9
9/24 13/5 13/16 13/22
15/15 16/24 17/5 21/5
34/13 36/25 44/12
66/25 71/13 72/16
75/17 75/24 85/22
90/14 100/10 120/1
121/7 124/3 132/21
134/23 143/20 160/10)
160/15 173/4 174/16
177/6 177/11 183/10
184/11 203/5
factor [1] 136/24
facts [5] 43/20 61/16
153/2 153/12 162/24
fail [2] 37/21 185/22
failed [4] 132/11
150/18 166/24 169/16)
failing [2] 113/6
172/14
failings [3] 62/2
62/16 203/14
failure [5] 71/16 74/2
150/12 156/17 203/19)
failures [2] 58/15
69/20
fair [9] 44/23 46/23
132/15 141/6 158/16
171/22 187/10 187/16)
200/10
fairly [3] 31/4 135/8
186/2
fairness [1] 147/14
faith [3] 199/2 199/13
200/9
Falkirk [1] 55/19
fall [1] 172/23
falls [1] 149/18
false [6] 9/10 9/17
37/19 48/13 148/20
149/7
falsely [1] 143/24
falsify [1] 181/25
familiar [2] 33/10
64/6
families [1] 186/15
fanfare [1] 168/13
fantastic [1] 181/15
far [27] 14/4 19/14
22/1 48/3 52/21 54/3
71/25 97/5 100/9
107/9 122/16 123/8
125/15 128/5 134/7
134/12 146/6 150/6
152/22 156/17 168/17)
179/1 190/15 191/18
195/16 197/12 198/25)
farming [1] 22/7
fashioned [2] 19/17
24/15
fat [1] 111/3
fault [2] 146/14
182/23
faulty [2] 55/12 56/19
favour [1] 142/25
fear [1] 92/7
feasible [2] 128/14
183/19
feature [1] 98/1
February [5] 115/8
139/12 139/17 140/22)
201/2
February 2014 [1]
139/12
fed [2] 161/2 197/3
feedback [2] 87/22
135/20
feel [5] 35/14 91/11
172/23 174/13 178/4
feeling [3] 75/12
82/16 83/4
fees [3] 12/24 13/17
85/1
feigned [1] 120/17
fell [1] 127/11
fellow [3] 2/24
110/17 193/8
felt [30] 2/1 7/21
16/15 18/13 31/7 47/5
47/8 58/24 62/10
66/18 71/15 71/24
73/16 77/17 83/1
85/24 86/21 88/18
91/14 91/23 95/8
95/14 95/18 97/13
97/15 104/4 172/19
172/22 174/12 175/19!
fence [1] 119/11
ferocious [4] 115/15
115/25 118/14 118/16
ferocity [1] 75/12
few [12] 22/25 27/6
53/11 119/14 131/17
133/19 176/12 179/2
180/1 187/14 198/18
203/13
fewer [1] 136/22
field [3] 63/2 82/5
139/3
fifth [1] 32/3
fight [1] 47/7
figure [4] 98/15
99/15 101/5 102/1
figures [7] 34/6
36/22 44/21 96/11
189/22 189/24 197/4
file [33] 19/21 21/7
23/5 23/14 23/23 24/1
24/8 24/14 24/16
24/21 24/22 25/9
25/11 27/10 27/24
28/2 28/17 29/4 29/5
29/6 31/9 52/23 54/12
141/2 145/24 146/10
148/21 170/9 170/10
170/14 170/17 176/18
176/21
filenote [1] 25/25
files [55] 19/10 19/14
19/18 19/21 19/24
20/9 20/10 21/2 21/9
24/4 24/5 24/14 25/12
25/14 25/16 25/17
26/2 28/23 37/9 43/16
47/10 47/12 47/14
47/15 47/20 48/1
49/14 51/22 52/10
52/18 52/22 53/2 53/6
53/8 53/17 57/9 57/10
57/23 58/2 58/2 58/7
59/7 59/10 66/4 106/4I
106/10 106/11 116/4
116/12 147/23 148/10}
150/3 155/11 156/9
170/11
filing [1] 25/13
filtered [1] 203/22
filtering [3] 200/17
200/18 203/18
final [10] 39/18 40/3
41/11 43/19 43/20
118/21 120/19 181/20}
182/16 196/22
finalise [1] 151/14
finalised [3] 28/20
43/14 151/9
Finance [1] 103/16
financial [5] 3/8
85/21 155/18 191/18
195/6
financially [1] 186/11
find [26] 6/7 34/5
36/21 42/21 47/16
66/25 84/13 118/10
121/2 133/5 141/8
151/22 160/10 160/16
167/6 175/1 176/20
177/23 181/12 183/10}
183/18 183/21 184/1
184/16 193/11 195/19)
finding [5] 85/22 98/5]
116/3 116/9 137/2
findings [3] 31/9
155/9 155/21
finds [1] 157/20
fine [5] 28/21 102/15
108/24 175/4 194/15
fingers [1] 111/3
finish [1] 191/25
finishes [1] 109/20
fired [2] 127/3 137/3
firing [1] 171/19
firm [3] 159/8 171/6
194/15
firmly [2] 66/14 66/16)
firms [3] 11/20 20/8
179/2
first [51] 5/10 15/22
19/22 23/10 23/11
23/16 29/4 29/6 35/24,
39/4 46/24 48/22
49/13 49/13 65/5
76/11 76/14 77/17
86/25 88/14 89/2
99/10 104/5 105/8
107/2 109/14 109/15
109/19 120/9 124/18
125/24 134/12 144/20}
145/13 145/20 157/3
167/1 168/11 168/15
169/7 169/19 177/10
180/16 181/2 181/6
183/15 184/11 192/13
199/5 201/23 202/12
firstly [411] 9/15 44/24I
51/13 52/5 72/6 87/11
91/2 117/5 156/2
163/3 171/5
Fiscal [1] 59/13
fit [4] 172/19
five [7] 7/8 32/22
101/18 118/13 151/5
154/8 157/2
five paragraphs [1]
7/18
five years [1] 101/18
fixed [1] 31/20
fixes [3] 54/14 54/14
144/8
flag [1] 118/2
flatly [1] 171/24
flawed [1] 96/16
flaws [4] 123/6
124/15 124/16 125/8
flew [1] 179/11
focus [10] 15/18
16/24 17/1 19/18 29/1
62/25 123/5 125/7
128/16 132/19
focused [4] 28/23
124/14 125/25 148/19)
focusing [2] 6/1 9/9
FOI [1] 99/25
FOIA [1] 100/5
foisted [1] 151/11
follow [7] 11/4 68/3
81/1 92/21 105/24
169/11 192/25
follow-up [2] 68/3
81/1
followed [3] 46/22
87/20 91/13
following [12] 5/19
31/21 36/19 60/7
97/19 148/9 148/16
161/25 185/12 197/14)
198/18 204/20
follows [2] 163/24
188/17
foot [11] 22/20 23/11
34/20 48/10 65/12
82/6 84/18 117/24
122/23 151/2 158/23
forbid [1] 157/13
force [1] 201/25
forced [2] 12/5 12/9
Forde [2] 196/20
198/4
foreign [5] 185/13
197/6 197/16 198/3
198/7
forensic [6] 4/3 7/25
41/17 112/2 136/20
155/18
forensically [1]
194/13
Forensics [1] 77/2
(64) explanation - Forensics
F
foresaw [1] 129/24
forgive [1] 172/18
forgiving [1] 186/3
form [10] 17/21 22/2
106/13 132/1 137/1
143/9 148/21 157/4
167/13 200/22
formal [2] 10/7
135/20
formally [2] 28/15
28/16
format [3] 30/25 78/5
167/13
formats [1] 78/7
formed [15] 18/6
43/8 46/25 52/6 53/25
62/14 72/23 73/22
85/19 88/17 113/8
114/25 128/8 167/4
189/3
forming [2] 18/1 52/1
forms [1] 131/12
formulate [1] 9/12
forth [1] 197/3
fortunately [2] 47/15
118/8
forward [11] 41/18
77/13 77/19 81/11
91/7 98/20 102/6
122/18 122/21 164/15}
178/5
forwards [6] 10/13
17/10 22/21 36/8 51/4
59/23
fought [2] 87/19
123/13
found [24] 17/6 22/15)
34/14 37/1 44/20 46/5
46/7 80/1 80/19 82/19)
113/2 116/3 118/9
128/5 131/10 131/11
143/14 147/22 154/8
164/12 183/16 190/12
193/14 194/25
founded [1] 38/11
founder [1] 203/3
four [8] 3/11 76/23
128/19 128/21 129/2
172/3 188/21 188/21
four paragraphs [1]
76/23
four years [1] 3/11
frankly [2] 85/8 142/4
fraud [10] 3/4 5/13
30/22 111/16 137/7
141/11 141/15 155/18}
173/18 173/21
frauds [1] 173/20
free [1] 17/17
Freeman [1] 130/18
Freeths [1] 177/12
frequency [2] 71/9
186/20
frequently [4] 88/4
88/24 116/16 171/12
friendly [1] 183/23
front [5] 34/19 34/20
103/3 196/20 197/21
front-end [2] 196/20
197/21
frustrated [3] 18/11
51/12 51/15
FUJ00232048 [1]
76/5
Fujitsu [28] 17/19
55/7 64/11 64/19
65/21 67/9 68/16
68/18 69/6 71/12
73/11 74/20 76/11
76/15 77/18 77/23
78/20 80/2 81/15 82/5
82/10 82/18 106/22
114/21 138/2 143/9
145/18 176/22
Fujitsu's [2] 118/4
118/25
full [9] 1/11 39/3
52/22 67/5 67/16
109/11 120/22 146/3
171/15
fully [4] 115/18
function [7] 114/11
147/21 147/23 152/8
172/3 181/18 182/6
functional [1] 182/4
functionality [1]
181/17
functionary [1] 195/8
functioning [3] 53/22
54/8 144/6
funding [1] 86/8
funds [3] 95/4 95/15
98/12
further [23] 7/14 18/5)
35/9 37/21 42/13 54/6)
59/7 71/17 73/19
75/17 75/21 78/23
79/4 86/8 91/7 94/7
95/20 104/15 107/11
139/6 169/22 189/24
205/8
fuss [1] 75/20
future [1] 178/8
gain [3] 11/15 199/10
200/5
gained [2] 148/2
150/20
gap [3] 73/16 201/11
202/11
gardening [1] 195/7
Gareth [32] 25/25
26/3 55/6 65/14 65/21
67/23 68/2 68/17
68/25 69/6 69/15
72/15 72/18 72/24
74/6 74/7 75/25 76/1
76/10 76/14 76/18
76/24 80/5 80/8 80/8
80/12 81/15 105/6
105/11 106/21 145/21
166/13
gathering [2] 117/12
175/5
gave [6] 74/10 82/12
131/24 153/20 191/20
200/14
GE [3] 111/15 137/5
137/6
general [13] 15/22
21/19 141/2 145/24
146/10 152/23 154/3
154/6 155/24 156/12
164/11 176/18 176/21
generally [3] 70/22
72/2 74/11
generate [3] 66/1
70/15 71/2
generating [1]
114/10
genuine [1] 46/8
geographical [1]
14/14
get [30] 14/18 27/1
28/11 44/25 45/4
51/19 51/22 59/9
75/22 81/16 81/18
95/18 100/9 100/19
111/22 112/6 115/21
117/15 119/21 125/20}
127/24 141/14 158/5
158/20 185/9 185/15
186/15 192/24 193/21
200/13
gets [1] 40/6
getting [12] 21/1 48/7I
63/12 70/20 85/20
103/19 117/17 119/18}
126/18 127/25 134/17
185/21
gifted [1] 143/5
give [16] 1/11 57/2
58/10 99/20 100/3
100/23 101/3 103/5
105/18 109/11 146/10
158/19 169/11 174/19]
190/2 191/9
given [21] 30/9 30/20
35/15 53/4 53/18
57/10 57/12 71/18
73/13 96/16 106/1
106/7 118/23 119/13
149/4 155/11 164/7
169/5 176/2 186/12
190/24
gives [2] 100/24
101/8
giving [10] 1/14 15/3
27/23 52/20 100/22
101/15 101/17 108/18
116/13 204/9
glad [1] 195/22
glaringly [1] 131/8
GLO [1] 177/14
Global [2] 111/13
173/18
go [56] 1/22 2/13 7/7
8/21 10/15 17/10
18/18 23/10 24/17
29/24 33/12 34/19
39/7 51/3 64/7 65/11
81/11 87/16 91/19
95/20 95/22 99/6
100/8 100/11 106/22
109/22 130/9 132/2
132/8 132/17 136/4
137/11 150/11 151/4
157/11 158/20 161/9
173/13 178/24 179/1
179/1 180/9 180/9
180/11 184/13 188/15)
189/11 190/15 191/11
192/13 193/2 193/2
196/8 196/10 197/10
201/1
go-to [1] 106/22
goal [3] 83/18 83/21
149/8
God [1] 157/12
goes [2] 99/13
178/14
going [65] 2/19 9/21
10/25 11/9 11/11
11/13 12/8 15/18
17/11 19/10 32/17
33/7 33/17 61/9 69/3
70/10 79/4 79/15
79/16 79/20 79/23
80/19 91/17 94/4 94/5)
95/5 95/6 97/21 99/23
101/13 102/6 103/13
104/17 122/3 125/21
128/2 132/8 133/4
138/10 138/17 139/22
140/14 146/11 151/3
157/14 157/23 158/3
159/8 160/14 161/4
163/9 163/10 163/23
163/25 175/14 179/15}
180/25 182/10 189/18}
194/9 194/11 194/11
194/12 200/17 204/6
gone [20] 44/7 44/8
44/15 44/16 46/11
99/18 123/4 125/6
125/17 141/15 141/21
142/12 149/14 154/13}
158/3 160/1 161/6
183/11 191/4 192/21
good [32] 1/3 1/8 1/9
50/25 77/6 82/4 82/5
83/14 83/16 93/15
94/5 109/4 109/9
1419/7 127/18 127/19
128/2 128/15 135/18
136/23 140/15 154/25)
155/3 161/1 168/3
174/9 176/24 181/24
199/2 199/13 200/9
203/21
got [49] 7/9 8/9 13/14
26/5 33/5 36/14 45/22
47/10 55/4 64/25
74/12 79/1 81/21 83/4I
93/19 94/2 103/22
103/23 103/25 108/2
110/25 122/5 124/17
124/24 138/9 139/15
139/25 142/11 142/11
145/24 147/8 150/17
161/7 173/6 173/10
183/21 184/18 187/12)
191/4 193/5 194/2
196/7 196/16 196/24
197/3 198/6 200/25
201/18 203/14
Government [4] 86/8
89/20 89/23 90/25
Graham [1] 33/13
grappled [1] 201/10
grateful [5] 42/23
99/22 108/16 180/13
204/10
gravy [1] 180/3
great [2] 72/9 85/5
greed [1] 136/22
Green [1] 177/20
grievances [1] 142/1
grinder [1] 172/21
grips [1] 141/14
Grocer [1] 143/2
gross [1] 189/14
ground [1] 67/15
grounds [1] 149/23
group [25] 11/8
14/16 20/3 20/4 29/25)
42/11 43/5 43/7 43/9
84/20 85/6 85/12 86/1
87/15 87/17 87/18
87/21 92/17 93/12
93/16 153/7 153/25
160/8 174/16 180/20
groups [1] 174/17
guess [3] 131/21
174/24 175/2
guilt [1] 203/20
guilt’ [1] 150/24
guilty [2] 37/19 137/2
H
had [273]
hadn't [11] 52/10
52/11 128/23 133/16
134/16 170/21 172/9
178/3 179/4 198/6
202/19
haha [3] 136/21
(65) foresaw - haha
H
haha... [2] 167/16
195/21
half [2] 130/1 155/6
halfway [1] 79/13
Hamilton [17] 24/4
28/24 30/8 33/22
34/13 35/3 35/21
38/18 39/9 40/14
40/19 45/9 45/19
47/16 48/12 168/15
202/6
Hamilton's [7] 29/5
29/8 30/4 32/20 33/12
38/25 46/12
hand [11] 30/7 31/19
32/11 44/3 44/6 44/13,
74/19 81/16 128/3
185/9 194/2
handed [2] 65/7
154/2
handle [1] 103/3
handled [3] 13/20
21/7 195/9
handling [2] 122/8
178/11
hands [2] 51/22
138/1
hang [5] 119/12
119/15 165/16 192/18
192/20
haphazardly [1]
19/16
happen [7] 10/8 75/8
87/18 123/17 129/18
157/8 177/18
happenchance [1]
29/3
happened [21] 14/18
21/10 32/14 32/18
38/23 47/25 48/24
50/12 55/23 58/5 59/3,
85/16 119/20 126/25
151/17 160/10 160/15
160/17 160/18 191/2
196/13
happening [3] 67/14
184/16 195/4
happenstance [1]
47/19
happy [4] 53/4 76/2
80/17 80/24
harbour [1] 195/22
harboured [1] 203/5
harbouring [1]
202/20
hard [13] 23/5 23/14
23/23 24/1 24/22
25/11 25/17 27/10
58/1 83/4 87/19
123/13 142/4
hard-copy [1] 58/1
hardened [1] 92/19
harder [1] 104/7
Harding [1] 181/5
hardware [1] 69/19
haring [4] 122/10
harmed [1] 84/23
harmful [1] 45/17
has [44] 2/10 5/11
5/16 30/21 43/17 44/9)
44/21 51/20 80/5
80/12 82/3 85/7 92/9
92/19 93/3 95/25
99/17 104/20 115/10
119/16 126/3 133/2
146/11 148/2 149/9
149/14 156/16 158/19)
159/16 165/5 167/10
168/23 171/18 179/9
179/21 180/3 185/7
190/23 191/2 191/4
191/7 194/9 195/6
196/7
hasn't [2] 164/16
180/2
have [241]
haven't [6] 26/13
138/9 142/15 145/24
188/8 189/19
having [11] 16/13
22/12 34/4 47/7 48/10
121/23 133/19 142/6
167/9 178/16 186/9
Hayward [1] 145/2
hazy [1] 153/17
he [134] 10/20 21/24
22/6 22/6 22/14 26/16
34/1 42/5 49/19 49/23
49/24 50/1 50/5 51/10
51/18 61/9 61/14
61/20 65/16 65/24
66/23 66/24 66/25
67/1 67/19 68/4 68/19
68/21 69/10 69/16
69/19 70/3 70/6 70/8
70/11 70/14 70/14
70/23 70/24 71/15
71/25 72/2 72/6 72/7
72/10 72/11 74/8 74/9)
74/10 78/25 79/1 80/9
80/23 80/24 80/24
80/24 80/25 81/4 82/2
82/3 82/9 82/14 82/16
82/17 82/18 82/21
82/24 82/24 83/1
84/22 85/7 85/9 85/10)
96/7 96/19 105/4
105/15 105/17 106/1
107/8 108/9 108/11
108/12 116/11 118/6
118/6 118/8 118/25
122/1 122/1 122/5
122/8 122/17 129/20
129/21 129/23 129/23)
135/2 135/6 138/6
139/12 139/13 139/14)
140/3 145/21 153/16
154/6 155/11 156/9
156/17 160/3 160/5
169/10 169/11 173/8
174/1 177/6 177/6
184/14 186/10 195/7
195/9
he'd [6] 71/18 71/25
129/22 167/24 169/9
202/8
he's [7] 81/17 81/18
122/5
head [11] 3/7 18/25
53/2 65/15 84/20
86/13 111/10 111/11
headed [3] 30/5
131/22 151/8
heading [1] 184/13
headquarters [1]
19/5
health [1] 191/21
hear [7] 1/3 51/1
67/24 83/14 109/4
154/25 192/10
133/2 144/20 145/13
145/20 165/25 177/5
180/15 181/4 201/9
hearing [3] 12/6
41/18 204/20
heavily [2] 21/21
50/9
heightened [1] 170/4
held [21] 5/23 21/8
28/1 41/4 43/16 47/13
53/6 53/22 54/8 59/10
64/3 84/9 98/9 101/9
101/21 106/10 123/1
125/4 136/25 144/5
187/22
hell [4] 114/23
help [24] 2/3 9/12
48/22 51/20 60/23
63/22 76/4 78/25
80/21 80/24 91/25
94/24 97/6 103/12
115/21 119/1 141/13
141/14 146/7 146/10
148/5 184/5 189/16
189/16
Helpdesk [1] 143/9
helped [1] 101/19
helpful [3] 79/1
123/11 204/4
helping [2] 117/13
177/25
Henderson [56] 1/5
1/6 1/8 1/13 2/20 7/12I
153/20 153/20 153/20
161/23 166/21 167/20
167/24 167/25 167/25)
182/11 182/12 183/16
82/8 82/8 96/19 96/20
111/13 111/16 173/18}
heard [11] 26/19 85/7
51/3 62/13 80/4 83/6
83/16 93/11 93/15
99/19 102/16 104/9
105/1 108/1 108/16
114/5 121/6 121/12
122/4 138/25 146/20
152/21 153/14 155/8
156/8 157/13 157/14
158/16 161/14 163/5
166/6 166/10 166/13
168/18 173/4 177/5
177/12 178/4 179/4
185/7 190/23 195/10
202/17 203/6 205/2
Henderson's [1]
102/12
her [25] 21/18 21/19
51/20 53/3 58/24
134/20 134/23 135/9
149/1 150/14 152/14
152/18 154/5 154/5
155/15 156/7 159/9
171/14 181/6 181/11
196/11
here [32] 6/10 8/24
16/23 22/21 27/22
94/9 96/5 101/23
103/13 110/9 117/24
122/23 125/11 130/2
131/1 132/6 153/24
154/18 158/14 163/7
165/18 175/2 180/14
181/1 184/16 193/9
193/19 194/1
Here's [1] 100/17
herself [3] 100/14
130/18 155/25
hesitate [2] 84/23
194/15
hesitation [1] 81/2
hide [1] 80/10
high [3] 81/14 82/2
96/12
higher [2] 111/23
159/8
highest [1] 179/11
highlight [1] 63/9
highly [2] 96/10
96/23
him [21] 22/14 26/1
38/12 73/13 79/2
80/18 82/14 106/24
107/1 107/5 108/12
122/9 139/15 153/13
153/15 153/23 166/7
166/19 168/3 169/15
173/13
himself [3] 121/22
183/15 183/17
hindsight [6] 67/21
24/8 27/2 27/21 44/12
104/10 104/13 104/19)
23/8 38/18 45/20 50/7,
57/9 62/17 81/8 92/25)
129/10 129/16 158/8
171/8 172/23
hire [1] 138/22
his [34] 22/10 46/5
65/25 66/9 70/14
71/19 72/3 74/9 81/2
81/16 92/8 103/15
105/6 118/7 118/24
121/12 122/13 138/16
139/13 139/20 149/1
150/14 155/9 155/10
156/18 160/7 160/7
160/8 162/22 166/23
167/17 167/18 169/2
181/11
his/her [1] 149/1
history [3] 88/16
88/18 193/11
hit [1] 131/14
hm [5] 111/25 123/18
161/16 163/13 176/15)
hold [5] 28/8 54/11
64/12 164/11 179/11
Hole' [1] 6/7
holes [1] 24/18
Holyoak [2] 42/1
139/10
homework [1] 22/12
homework’ [1] 159/6
honest [1] 81/20
Hooper [3] 116/19
180/20 184/12
hoots [1] 190/2
hope [6] 90/25
122/20 142/16 178/22!
188/8 189/19
hoped [1] 123/15
hopefully [2] 51/19
189/4
Horizon [66] 3/24
6/14 7/2 7/15 8/6 8/8
8/10 8/25 16/25 17/7
17/16 17/22 18/2
30/19 30/21 34/4
36/20 38/9 53/23 54/2
54/9 55/11 56/1 56/19
57/6 60/14 65/15
67/25 68/8 68/10
68/20 72/20 73/10
73/12 74/13 74/22
97/23 105/19 112/4
112/13 113/20 114/10)
114/16 114/20 114/21
124/15 124/16 126/2
128/6 132/23 141/5
143/23 144/7 147/24
162/4 162/8 166/23
167/20 180/3 181/8
183/13 191/3 195/19
195/24 197/4 197/18
Horizon' [2] 123/6
125/8
Horizon-related [1]
14115
(66) haha... - Horizon-related
H
hours [4] 70/8
179/22 179/22 185/25)
house [3] 12/8 92/12
93/1
hovering [1] 163/18
how [38] 6/14 17/3
19/14 22/17 32/18
51/25 52/3 52/12
64/14 70/23 84/7
86/12 87/19 99/22
99/25 108/1 120/21
128/7 140/13 140/15
142/4 142/7 142/10
146/4 147/2 164/1
167/12 167/21 177/5
178/13 182/2 182/6
182/13 183/5 186/1
198/5 200/5 200/22
Howe [1] 202/14
however [11] 7/21
12/23 37/10 43/17
44/8 47/3 90/22 98/2
99/17 143/14 150/16
Huddle [4] 42/11
42/13 42/15 47/23
huge [4] 86/3 104/4
134/6 183/12
hugely [1] 131/20
hundred [1] 187/14
hundreds [2] 98/8
104/1
hyperbole [1] 174/7
hypothesis [2] 189/3
193/17
l accepted [2] 136/18
172/20
l actually [1] 192/4
lagree [1] 100/21
l allowed [1] 172/23
lalso [1] 66/22
lalways [1] 12/22
lam [7] 42/12 42/25
79/20 103/5 122/5
133/20 151/3
l answered [1]
122/20
l apologise [3] 70/10
125/11 200/2
lask [5] 1/10 93/10
109/10 174/14 194/23)
lasked [3] 21/8
190/22 198/4
l associate [1] 84/1
lassume [3] 25/15
49/22 204/5
lattach [1] 42/11
Ibe [1] 142/19
I being [1] 154/1
I believe [8] 11/21
68/18 93/25 107/24
155/14 189/22 192/9
198/20
I believed [1] 136/15
I call [2] 1/5 109/6
I came [2] 29/4
170/12
I can [8] 16/10 52/21
56/4 125/19 155/1
191/18 197/12 200/21
I can't [15] 22/18
23/16 23/24 28/19
49/1 55/3 65/6 73/7
76/2 78/17 87/14
119/15 146/14 161/8
164/9
I certainly [2] 73/15
75/18
I checked [1] 28/2
I continued [1] 85/2
I could [3] 20/19 28/4
48/12
I couldn't [1] 163/17
I described [1] 19/17
I did [9] 22/4 48/19
79/1 129/24 146/21
164/6 166/14 170/19
200/2
I didn't [10] 35/18
48/5 59/19 158/18
161/9 167/15 171/22
176/23 193/17 195/21
I discussed [1] 25/24
Ido [14] 6/25 12/5
17/3 25/16 28/19 33/1
33/3 70/11 70/19 71/5
87/14 93/8 99/19
108/3
I don't [31] 10/6
10/14 11/18 12/6
15/14 16/13 50/11
53/24 59/15 72/6 76/5
87/19 101/20 101/23
102/18 105/9 110/25
135/23 138/14 138/14)
153/15 158/18 160/22)
161/1 164/9 168/1
173/10 176/23 176/24}
177/22 193/20
I doubt [1] 160/24
I encouraged [1]
118/7
l expected [1] 106/11
I feel [2] 91/11
172/23
I felt [17] 18/13 31/7
47/5 66/18 71/15
73/16 85/24 95/8
95/14 95/18 97/13
97/15 104/4 172/19
172/22 174/12 175/19)
I find [1] 167/6
I first [5] 19/22 23/16
49/13 88/14 184/11
I formed [2] 46/25
53/25
I found [2] 34/14
82/19
I get [1] 81/16
I go [3] 18/18 132/2
197/10
I got [4] 81/21 142/11
184/18 193/5
I guess [1] 131/21
I had [27] 18/6 21/17
21/17 25/16 25/17
26/2 28/1 73/17 74/5
75/7 76/14 86/4 90/20
118/9 118/13 122/16
137/1 152/5 155/24
156/23 158/17 163/23}
168/17 170/23 171/11
171/23 198/6
hadn't [1] 134/16
I harbour [1] 195/22
I harboured [1] 203/5
Ihave [12] 2/11
27/24 89/14 99/18
119/16 125/9 133/15
135/1 143/4 167/11
173/23 191/7
I haven't [2] 188/8
189/19
hesitate [1] 194/15
I hold [4] 179/11
I hope [4] 122/20
142/16 188/8 189/19
limagine [1] 81/22
linclude [1] 144/15
lincreasingly [3] 2/1
88/17 91/23
lintended [1] 125/9
I just [6] 16/15 20/20
27/1 44/8 59/20 68/6
I kick [2] 135/22
199/20
I knew [3] 21/19
167/21 169/7
I know [8] 93/11
153/17 167/11 168/2
170/18 173/15 174/15}
179/17
I later [1] 136/15
Hook [2] 92/2 129/25
looked [5] 29/6
163/16 169/8 170/22
173/4
I made [4] 66/18
110/24 135/4 186/18
I making [1] 27/20
I may [6] 2/20 26/15
59/20 116/7 120/16
175/21
I mean [50] 7/19 8/8
9/17 9/17 10/8 11/18
12/22 21/17 24/3
25/15 28/12 29/3 29/3,
31/5 33/1 35/7 55/4
71/17 80/4 81/1 85/6
85/13 86/16 89/3 91/8
97/25 98/10 101/20
103/25 108/11 119/4
120/23 121/21 122/5
127/20 135/11 138/8
146/9 146/12 161/6
175/7 179/13 180/3
182/3 184/8 192/19
198/2 199/15 199/22
202/8
I meant [1] 163/21
I mentioned [4]
70/23 175/7 182/3
193/6
I met [3] 65/14 68/15
203/9
I might [3] 135/17
135/18 147/10
I must [2] 72/17 75/4
I need [4] 57/21
I needed [1] 157/1
I never [1] 151/14
Inot [1] 180/1
I note [1] 177/10
I now [4] 134/15
136/5 172/22 199/19
l omitted [2] 104/13
122/14
I only [3] 20/21 68/2
178/22
I probably [7] 71/24
82/25 121/25 146/13
157/7 161/6 164/5
I prolonged [1]
204/11
I raised [2] 48/17
50/11
I realised [3] 23/7
23/20 69/15
really [1] 16/14
I recall [14] 24/4
25/24 66/17 73/5 75/4
77/13 78/6 78/15
135/14 146/23 146/24}
152/20 152/22 153/25]
I recognised [2]
13/19 167/15
I regard [1] 90/24
I regarded [1] 13/2
l regret [2] 15/15
161/5
I remember [5] 85/13)
85/23 147/18 166/18
181/5
l represent [1] 93/16
I requested [1] 81/1
I responded [1]
159/12
l reviewed [1] 170/12
I revisited [1] 27/24
Iright [4] 142/21
I said [9] 84/22 84/22
98/11 98/21 146/9
152/18 155/15 157/10
184/17
I saw [2] 82/14
116/13
I say [4] 11/114 134/11
138/5 163/22
I see [7] 6/17 25/13
79/9 126/24 131/3
152/7 201/17
I seek [1] 111/23
I seem [1] 19/23
I should [5] 104/18
157/24 172/20 191/25)
198/17
I showed [4] 161/14
I simply [2] 28/11
176/5
I sort [1] 135/15
I spent [1] 18/22
I spotted [1] 49/16
I stand [1] 151/15
I started [1] 20/9
I still [2] 165/14
174/13
I strongly [1] 203/12
I subsequently [4]
23/3 23/13 27/9 31/9
I suggest [1] 132/10
I suppose [1] 165/12
I suspect [8] 6/23
11/18 46/14 152/5
159/14 174/21 175/1
190/10
I take [2] 53/15 90/3
Itell [4] 173/15
I then [1] 195/18
I think [162] 2/24 4/2
4/14 7/10 7/19 8/16
11/6 13/13 14/14
15/22 16/4 17/3 18/8
18/19 19/11 19/16
21/19 24/2 25/24 26/1
27/22 27/24 31/7
34/16 42/5 46/23
47/25 48/6 51/7 52/17
53/10 54/11 54/19
55/5 57/25 60/1 61/1
62/5 62/7 62/10 62/19I
63/9 63/18 64/11
64/16 65/1 67/13
69/14 71/24 73/22
74/5 74/18 75/19
75/23 76/14 76/15
78/18 79/4 79/7 79/8
79/20 79/21 81/24
82/10 82/24 83/24
84/9 84/12 85/18 86/6
90/10 91/4 94/1 98/6
99/24 103/17 104/18
105/9 105/21 105/23
105/24 106/4 106/19
107/20 108/15 109/16)
110/14 110/23 116/1
117/8 125/10 126/3
127/20 128/9 128/10
(67) hours - I think
I think... [67] 128/11
128/14 128/20 129/11
129/21 129/23 130/6
134/11 136/16 136/23
139/13 140/12 140/19)
141/1 144/21 146/12
147/8 151/10 151/11
151/11 152/19 153/14}
153/16 157/6 157/25
160/4 161/8 161/11
161/12 162/11 163/21
164/22 165/13 169/7
169/10 169/14 170/10)
170/19 171/22 172/5
174/17 176/9 176/13
177/24 178/1 178/14
180/1 181/5 182/7
182/24 183/8 194/9
195/6 195/23 195/25
197/5 197/21 198/17
198/22 199/7 199/25
200/19 202/3 203/6
203/17 203/22 204/13
I thought [2] 26/16
156/25
I told [1] 75/5
I took [4] 73/20 85/1
120/13 120/13
I turn [3] 4/13 63/20
171/2
I twigged [1] 120/15
I understand [2]
27/19 197/22
luse [1] 187/7
l usually [1] 204/5
I visited [1] 76/15
I want [3] 22/22 29/7
79/21
I warned [1] 115/2
Iwas [62] 3/21 16/1
17/17 17/21 19/8
22/11 22/13 23/19
24/2 25/18 29/4 34/5
35/11 36/21 47/12
48/25 49/25 53/3
57/22 69/24 70/19
71/18 71/25 72/16
72/17 72/20 73/17
74/5 74/5 74/19 74/21
74/25 78/17 85/11
91/4 104/17 106/10
106/20 118/15 119/21
120/9 120/13 121/22
122/3 122/10 126/13
133/20 146/3 146/5
154/16 155/16 156/18}
163/18 163/19 163/19)
163/19 165/21 170/22)
171/12 172/20 196/22
201/7
I wasn't [3] 120/10
122/9 200/3
Iwill [4] 107/25
I wish [8] 90/18
129/11 131/23 131/25)
144/25 164/7 171/11
171/23
I wonder [2] 154/13
180/10
I worded [2] 163/17
164/10
I would [20] 42/23
79/11 84/25 89/15
99/22 106/12 111/1
116/6 120/6 134/9
147/9 174/24 175/12
175/16 179/6 186/2
190/15 193/8 199/16
201/4
I wouldn't [1] 175/11
I writing [1] 41/8
I wrote [1] 152/8
I'd [26] 2/11 55/6
58/6 67/23 72/21 83/4
85/19 89/2 89/5 98/6
100/21 101/14 109/20)
115/2 122/12 142/13
147/2 154/4 154/5
164/7 175/2 179/1
179/1 185/22 187/18
188/12
Til [6] 102/25 125/2
175/22 183/8 184/9
203/7
I'm [63] 2/10 2/19 5/7
10/9 11/13 12/21 14/4
17/9 17/12 21/4 24/19)
27/2 28/10 28/17 29/7
32/17 32/18 33/7
33/17 48/3 49/2 55/8
55/14 61/11 62/13
65/2 69/3 69/21 76/2
79/15 79/15 80/12
80/17 91/17 94/4
102/6 107/9 108/16
116/3 117/16 131/21
132/7 134/14 151/10
151/13 153/16 159/15)
161/9 161/10 162/19
163/17 164/10 165/13}
168/17 170/18 171/22)
174/21 175/1 180/24
194/15 195/22 204/10;
204/10
I've [35] 79/1 79/9
79/22 80/1 80/1 83/4
93/19 102/21 104/12
110/25 116/3 124/17
124/17 125/10 130/17,
134/15 136/25 142/12)
143/17 146/25 151/22)
163/20 167/14 173/16)
173/17 173/18 173/19)
173/24 187/24 192/12)
192/21 195/22 201/9
201/18 202/23
lan [39] 1/5 1/6 1/13
7/12 80/4 81/13 81/21
81/21 96/9 116/2
116/9 121/22 122/7
122/15 124/1 128/14
129/11 129/17 136/21
140/16 146/10 152/21
153/9 153/14 153/16
154/1 155/8 156/16
156/24 158/18 158/19}
163/23 167/10 167/20
170/10 170/12 170/22
193/7 205/2
lan's [4] 145/20
iceberg [1] 20/20
ID [1] 37/2
idea [8] 77/6 127/18
127/19 128/15 161/1
174/20 199/5 199/11
identified [6] 30/21
63/11 80/18 87/2
151/6 202/23
identifying [2] 9/11
9/20
ie [17] 7/4 49/20 71/2
92/22 106/16 112/7
117/6 118/4 153/2
154/10 161/3 164/11
164/23 167/5 170/15
175/12 199/10
ie at [1] 199/10
ie back [1] 167/5
ie both [1] 153/2
ie had [1] 49/20
ie one [1] 175/12
ie picking [1] 164/23
ie Post [1] 92/22
ie that [1] 106/16
ie the [5] 7/4 71/2
112/7 161/3 170/15
ie up [1] 117/6
ie when [1] 154/10
if [152] 2/13 2/20
5/14 6/3 6/17 7/7 7/8
8/14 8/21 10/16 10/18
11/15 12/7 14/23
17/10 21/5 23/10
28/12 30/12 31/11
31/11 31/19 32/3
32/11 33/10 33/12
33/16 34/18 35/23
36/8 36/24 39/6 42/23
44/1 44/2 44/6 44/13
47/19 59/20 60/2
60/18 60/21 61/1
61/22 62/13 63/17
63/23 64/6 66/6 66/18
71/15 75/9 76/22 79/5
79/9 81/18 82/4 84/22
85/2 85/25 89/11
89/25 90/20 91/9
91/10 91/13 92/10
94/6 95/4 95/14 95/21
95/22 96/12 97/19
98/14 99/4 99/6 99/15
100/4 100/8 100/19
100/22 100/23 101/15)
101/16 105/1 107/23
108/6 109/22 114/9
114/17 117/20 124/17
125/19 129/12 130/9
130/25 132/4 137/11
139/19 141/22 150/11
154/16 156/20 157/12}
157/16 160/7 162/15
163/24 164/19 164/21
165/10 167/23 169/25}
172/20 173/2 175/22
178/3 178/18 179/4
181/5 182/8 182/11
182/12 183/11 183/19}
185/3 185/13 186/2
186/3 186/8 187/4
187/6 187/19 187/25
188/12 188/15 190/4
190/7 192/13 193/16
194/25 194/25 196/1
196/5 196/5 196/13
197/22 201/17 202/6
202/21 204/6
ignorance [1] 120/17
ignored [1] 9/19
ignores [1] 178/17
IH [1] 7/9
illogical [2] 118/19
119/2
image [1] 86/16
images [1] 170/11
imagine [2] 81/22
103/5
immaterial [4]
131/20 186/22 188/2
188/3
immediately [6]
18/24 59/11 147/18
172/11 175/16 182/16
immensely [1] 46/7
immunity [2] 26/10
26/17
impact [11] 39/15
64/4 97/2 97/9 131/14)
131/18 181/4 182/18
182/21 184/4 186/5
impacted [1] 186/6
impacts [1] 186/15
implications [3] 66/7
71/21 73/23
importance [1] 20/23
important [7] 24/7
34/9 34/12 35/19 45/8
155/13 159/19
importantly [1]
177/23
impossible [1] 8/12
impressed [4] 166/4
166/6 166/7 166/19
impression [5] 11/15
27/16 53/25 72/23
150/20
improper [1] 200/15
improperly [1] 43/2
improved [1] 52/4
inadequate [1]
116/14
inadequately [1]
119/6
inappropriate [2]
85/14 93/4
inattention [1]
156/14
inch [1] 200/14
incident [3] 54/16
54/18 144/10
incidentally [1]
136/25
include [12] 5/18
14/9 29/18 36/10
52/19 61/12 61/24
69/22 143/8 143/13
144/15 162/20
included [16] 23/4
23/23 25/21 27/10
28/7 38/8 40/9 52/23
62/22 106/4 123/11
124/5 143/18 165/6
189/7 190/18
includes [2] 36/19
101/16
including [14] 15/3
43/6 54/25 65/18 66/4
88/21 92/17 101/2
110/2 143/7 144/7
145/8 193/24 202/14
inclusion [1] 38/11
incoming [1] 183/4
incompetent [1]
179/14
incomplete [2] 129/4
182/3
inconclusive [1]
10/10
inconsequential [1]
131/15
inconsistency [3]
48/17 49/16 84/12
increased [1] 140/19
increasing [1]
138/21
increasingly [7] 2/1
51/12 51/15 87/9
88/17 91/20 91/23
incredibly [1] 81/14
incur [1] 78/23
indeed [10] 9/1 29/10)
29/14 62/18 92/11
132/18 133/12 151/6
185/9 193/3
independence [1]
82/13
independent [11]
5/11 5/16 10/22 72/19)
75/7 82/9 89/19 112/1
(68) I think... - independent
independent... [3]
158/6 159/5 178/25
independently [2]
7/5 155/21
indicate [1] 139/19
indicated [1] 150/7
indications [1] 72/13
indistinguishable [3]
66/2 70/16 71/3
individual [13] 14/7
15/19 17/20 24/16
25/10 65/24 67/10
82/3 98/13 101/22
101/25 104/3 131/20
individuals [2] 57/12
115/11
ineffective [1] 62/1
inexpensive [1]
149/8
inexpert [1] 63/2
inference [2] 96/15
123/7
inferring [1] 6/18
inflated [2] 34/7
44/20
inflated’ [1] 36/23
influence [4] 92/15
120/18 121/16 121/20}
inform [3] 54/13
54/16 54/21
information [35] 14/1
35/19 38/15 41/15
42/14 45/8 45/16 47/6)
58/9 66/12 74/13 96/9
96/23 99/12 99/16
99/21 100/3 100/4
101/1 101/16 103/6
105/12 108/2 108/5
112/12 112/15 113/4
417/12 117/12 117/15
151/22 157/9 175/5
178/5 194/5
informed [2] 79/22
132/18
inhibited [1] 35/14
initial [14] 29/1 30/5
46/21 49/3 53/9 55/8
58/20 90/6 117/5
125/15 126/25 127/8
132/3 134/20
initially [4] 47/14
112/19 115/19 135/24}
innocence [5] 6/2
137/1 149/1 150/1
156/20
innocent [1] 137/3
inordinate [1] 117/18
input [4] 66/9 156/18
165/16 165/22
inputs [1] 6/13
inquiry [27] 1/11
14/24 23/7 23/20
26/12 26/13 26/21
28/3 69/25 70/13 85/7
89/14 90/19 104/19
108/17 109/10 109/13}
115/10 133/2 168/23
174/25 178/23 180/15)
181/4 190/25 191/8
193/7
Inquiry's [1] 192/16
inserting [1] 145/19
insight [2] 148/2
200/5
insignificant [1]
186/22
insisted [2] 90/12
136/2
insistent [1] 73/8
insofar [1] 114/7
instance [1] 77/18
instances [2] 84/5
142/10
instead [5] 72/25
92/18 163/14 166/7
172/21
instincts [2] 9/8
192/25
Institute [2] 2/24
110/17
instructed [5] 5/16
6/5 143/19 169/1
169/15
instruction [1] 132/3
instructions [2]
35/12 92/22
insufficient [1] 37/15
integrity [5] 17/18
97/22 109/20 114/16
143/16
intended [5] 35/13
38/4 125/9 132/12
158/4
intense [1] 121/9
intentions [1] 134/18
interest [4] 26/10
51/24 94/2 104/20
interested [8] 54/3
83/3 94/24 95/1
137/22 159/25 184/24)
189/25
interesting [1]
103/18
interests [3] 38/5
45/17 94/1
interfere [2] 121/15
121/19
interim [36] 16/17
17/14 17/25 18/3 27/7)
28/14 28/20 107/24
108/4 117/6 122/25
123/5 123/12 123/16
123/19 123/20 123/22)
124/10 124/11 125/6
125/25 126/5 126/9
126/14 127/2 130/14
130/25 140/7 148/16
157/21 158/1 158/10
161/20 165/7 165/12
186/11
internal [10] 5/6 5/7
48/14 51/5 52/23 68/4
102/7 111/10 115/10
116/16
internally [2] 50/12
91/6
International [1] 4/2
intervenes [1] 82/6
Interview [2] 5/25
44/11
interviewed [3] 7/1
148/11 148/20
interviewee's [1]
148/25
interviewees [1]
150/13
interviewing [1]
175/10
interviews [2] 148/22
150/21
into [44] 8/9 8/25
13/14 29/10 31/2 51/6)
52/2 55/10 58/4 62/21
63/14 63/17 69/14
70/10 70/20 94/5
97/21 103/9 104/1
108/19 111/22 112/3
116/17 119/10 124/8
128/17 129/15 131/22
132/8 137/9 148/3
157/20 172/24 183/12I
189/23 190/12 191/2
194/13 194/13 195/1
197/4 200/5 200/22
203/24
intricate [1] 132/23
introduced [1]
106/24
introduction [1]
35/25
introductions [1]
92/21
inured [1] 165/8
invented [2] 196/9
196/13
inventing [1] 165/13
invested [1] 140/13
investigate [3] 37/10
67/17 138/21
investigated [7] 14/6
63/3 104/5 127/25
129/2 173/20 190/11
investigating [8] 3/4
88/5 89/1 104/6 123/4
128/13 176/7 181/11
investigation [73]
4/23 6/10 11/25 13/11
14/22 16/7 18/21 29/2
29/19 30/3 30/6 31/8
33/14 36/5 37/4 37/6
39/19 43/10 43/23
46/21 49/4 53/9 53/20
54/24 55/25 56/13
56/22 58/14 60/10
60/18 60/24 90/7
92/13 112/3 113/19
114/11 115/16 115/18)
116/14 116/20 117/6
123/16 124/5 126/20
128/7 137/8 137/25
138/4 139/12 139/23
140/3 141/1 141/12
142/3 142/5 145/9
147/1 147/6 147/23
147/24 148/3 148/11
150/9 150/23 150/25
160/6 171/7 173/18
178/19 178/22 178/25}
190/18 202/1
investigations [29]
3/3 3/7 3/15 30/13
31/2 34/1 52/2 52/3
52/7 52/12 53/13 62/2
62/15 71/22 73/4
83/20 88/20 105/13
111/12 111/13 124/6
137/9 147/21 148/15
148/18 152/8 152/15
195/19 197/9
investigative [3]
149/20 150/21 192/25]
investigator [16]
33/3 33/25 34/9 35/9
37/1 44/19 52/24
52/25 140/16 141/9
150/7 150/16 150/17
173/16 175/9 178/18
Investigator's [1]
36/11
investigators [15]
5/25 7/2 39/13 42/1
52/11 52/20 138/23
139/6 139/9 141/14
148/18 148/24 149/14}
193/9 203/7
investigatory [2]
4/16 193/24
Investments [2]
185/2 190/5
invitation [3] 118/8
171/16 171/19
invited [2] 118/6
133/23
involve [1] 6/11
involved [9] 3/23
48/4 121/22 125/16
127/21 127/23 138/2
141/20 200/7
involving [7] 29/8
56/6 75/25 87/16
87/24 141/19 144/23
Ireland [3] 14/10
14/19 197/4
irrespective [6] 47/1
71/8 74/9 83/20 84/8
85/17
irritated [2] 126/19
163/20
is [319]
Ismay [2] 99/8 195/8
isn't [5] 114/1 143/11
146/12 163/15 171/8
issue [33] 9/18 15/8
29/8 51/11 63/20 64/2I
66/18 66/22 66/24
67/4 67/17 75/9 75/10)
104/19 114/9 117/16
118/4 123/6 124/14
124/15 124/15 125/7
159/19 159/21 159/22)
168/25 175/25 183/10)
188/6 188/14 198/2
201/16 201/17
issues [26] 13/8
13/23 15/2 15/6 15/9
16/23 16/25 17/6
18/10 29/15 54/8
65/18 68/8 68/10 91/6I
111/23 112/12 121/24}
126/9 127/10 127/17
143/16 158/4 191/1
201/9 201/10
it [599]
it'll [4] 5/1 7/9 117/21
183/3
it's [83] 1/15 4/14
4/20 4/25 5/4 6/22
8/18 9/23 10/17 14/23}
15/7 16/14 18/20
20/12 26/5 29/10 30/5I
31/19 32/10 32/12
33/13 33/16 35/7
35/23 38/24 39/4
41/24 44/7 44/9 44/10
44/15 44/16 50/18
57/17 68/10 70/19
76/7 79/9 83/7 84/4
90/12 92/4 92/9 93/23)
93/25 94/4 95/24
97/25 100/10 102/5
104/19 104/22 107/23)
109/15 110/9 112/19
124/25 130/10 133/4
134/16 134/22 135/10)
135/12 138/16 142/4
142/16 147/14 154/13)
157/25 161/22 162/11
171/22 173/15 174/12)
174/17 188/2 188/2
188/3 192/19 194/17
201/11 202/4 202/5
items [4] 186/4 190/9)
191/12 193/14
iteration [1] 7/15
its [35] 18/10 37/5
39/23 40/23 45/17
45/24 52/20 55/12
68/22 73/1 79/10
(69) independent... - its
its... [24] 86/22 89/22
92/11 92/11 92/12
94/7 97/4 97/11 113/9
134/3 141/14 142/6
146/22 147/17 148/12)
148/13 151/10 153/6
157/20 171/25 177/16)
187/8 189/6 189/13
itself [14] 6/12 15/14
56/2 106/14 114/4
124/20 138/13 143/11
181/8 181/15 182/17
183/3 188/22 200/16
J
James [7] 12/4 81/10
83/24 92/8 92/18
116/18 122/12
Jane [3] 41/25 76/9
172/8
Janet [1] 92/5
January [6] 102/9
102/23 103/17 152/20)
201/2 201/5
January/February [1]
201/2
JARB0000022 [1]
6/21
Jarnail [16] 18/24
19/12 21/13 21/23
48/2 48/18 48/19
48/23 50/4 50/9 50/11
51/21 55/9 58/23
58/25 145/22
Jarnail's [1] 58/25
Jason [5] 1/10 56/5
109/9 144/22 177/24
Jenkins [51] 25/25
26/3 55/6 65/14 65/21
67/18 67/23 68/3
68/17 68/25 69/6
69/15 69/25 71/10
71/20 72/4 72/15
72/18 72/24 74/4 74/6
TAIT 75/25 76/1 76/10)
76/12 76/15 78/11
78/24 80/12 80/22
81/8 81/15 82/12
104/22 104/22 105/6
105/11 106/8 106/16
106/21 107/10 145/21
166/4 166/6 166/13
167/2 168/21 169/2
169/5 169/13
Jenkins’ [1] 80/5
Jeremiah [1] 179/22
JFSA [11] 10/21
12/16 61/17 92/8
123/10 125/16 128/10}
137/16 137/19 148/2
162/25
Jo [11] 24/4 28/24
29/5 32/20 47/16
48/12 160/4 196/2
196/11 196/15 202/6
Jo's [1] 196/5
job [18] 11/21 13/13
13/14 124/3 124/3
124/4 124/10 124/13
124/18 124/20 125/22)
125/22 126/4 135/2
135/24 135/25 179/20)
194/17
Job 1 [4] 13/13 124/3
124/4 124/18
Job 2 [2] 13/14 124/3
jobs [1] 173/17
JOHN [4] 109/7
109/12 147/1 205/12
join [3] 139/12
139/23 140/3
joined [2] 3/14 75/24
joint [1] 64/2
Jones [3] 173/8
174/5 174/19
Josephine [7] 29/8
30/7 35/21 40/19 45/9)
45/19 46/12
journalistic [1]
189/19
judgement [1]
120/16
judgments [1]
142/23
Julie [2] 56/6 144/24
July [23] 6/22 8/15
16/17 17/13 29/10
62/18 76/1 76/7 81/11
94/11 95/25 104/23
105/4 107/3 107/25
117/6 123/20 139/23
139/25 157/21 160/21
168/7 170/1
jumped [1] 51/4
June [17] 1/1 4/22
5/4 6/10 22/25 23/15
27/6 27/19 28/13
38/24 41/22 41/22
49/6 110/7 133/16
135/9 140/20
just [117] 1/22 7/7
8/14 8/16 14/18 15/5
16/15 17/12 19/11
20/20 22/25 24/8 27/1
27/2 27/6 28/14 28/18)
29/14 32/11 33/10
35/23 36/2 36/5 36/13
36/18 39/10 40/5
43/20 44/8 44/13
46/11 48/8 49/11
50/13 53/1 57/20
59/20 60/6 61/8 68/6
69/3 77/8 79/13 79/21
80/1 81/11 81/13 93/6
97/6 98/15 99/4 99/18
100/11 101/13 102/21
104/18 105/2 107/22
107/23 110/2 117/13
119/13 120/7 121/2
123/19 125/20 126/8
126/17 128/16 130/2
132/14 135/1 135/23
135/25 136/4 142/16
146/5 146/14 147/15
151/13 151/24 154/13
156/5 157/15 158/2
160/25 161/24 163/3
164/4 164/20 167/20
167/24 170/25 172/13
172/14 172/14 175/25]
176/12 177/1 180/24
181/16 182/15 183/23
183/24 187/24 193/2
193/9 194/11 194/22
195/11 195/18 196/22
199/22 200/21 201/1
201/23 203/18
justice [15] 10/20
38/6 45/5 58/10 58/13
59/5 59/22 60/22 61/6
61/23 62/1 62/15 88/6
89/1 107/14
justification [1]
119/6
K
Kay [3] 137/19 179/8
179/11
Kay Linnell [1]
137/19
keep [4] 6/3 30/14
79/22 179/17
keeping [1] 176/17
KELs [2] 56/15 145/9
ken [1] 120/8
kept [2] 25/14 176/22
key [2] 80/5 154/2
keystrokes [4] 66/1
70/16 70/17 71/2
kick [3] 135/22
161/10 199/20
kicked [1] 48/6
Kim [1] 139/23
kind [9] 7/18 29/15
97/23 118/11 143/5
143/7 151/13 159/23
175/2
kindly [4] 51/20
King [7] 105/5 156/1
158/25 159/4 160/15
161/4 203/22
knack [1] 120/14
knew [18] 21/19
34/12 59/8 63/17
72/24 75/23 113/17
114/6 114/8 116/12
118/18 140/13 146/3
146/14 167/21 168/25)
169/7 190/1
know [87] 1/10 10/13
11/18 12/6 14/1 15/14)
18/5 19/19 20/17
20/17 20/20 20/21
21/5 22/12 25/17 26/1
31/6 35/1 35/5 39/5
50/12 55/15 55/17
59/9 59/17 61/25
67/24 72/7 74/23
79/23 80/5 80/13
80/17 82/4 82/9 86/12,
87/19 93/11 95/2 97/5)
99/19 101/20 103/25
104/7 105/17 105/22
107/23 114/7 126/11
129/23 130/11 131/24}
136/4 136/5 136/19
136/19 141/16 142/6
146/13 147/4 153/17
153/23 160/22 161/1
163/16 164/20 165/12
165/19 167/11 167/23}
168/2 169/5 170/18
172/15 173/15 173/18}
174/15 177/21 178/21
179/5 179/17 180/19
183/21 184/16 184/19
187/23 195/7
knowing [1] 149/7
knowledge [14] 2/16
17/20 22/10 65/23
70/2 74/12 110/4
110/11 119/25 122/16}
140/14 154/11 166/5
180/4
knowledgeable [1]
68/22
knowledgeably [1]
73/12
known [10] 33/2
55/19 55/20 56/14
56/15 57/6 114/20
195/4 195/13 195/15
knows [1] 81/15
KPMG [6] 189/23
191/8 192/5 194/4
194/6 194/16
L
lack [7] 30/23 31/8
51/11 51/15 58/14
89/18 141/2
laid [1] 135/15
language [7] 17/12
78/9 121/4 121/20
132/15 157/7 172/19
large [2] 4/9 93/16
largely [1] 133/18
larger [2] 20/4 59/8
largest [3] 3/8 173/19]
189/20
last [11] 23/11 26/9
94/19 105/1 109/22
189/21 190/22 192/3
203/2 204/6 204/6
Lastly [1] 140/3
late [4] 58/19 59/20
108/5 191/9
later [33] 6/22 9/14
10/3 27/14 28/13
29/10 55/5 59/25 71/4I
119/11 120/9 129/25
130/1 136/15 137/14
145/14 148/6 151/18
152/14 152/20 160/16)
161/13 167/17 167/17)
172/7 175/14 175/16
175/19 179/13 189/12)
189/23 189/24 199/22)
latter [1] 152/20
laughed [2] 24/20
159/2
law [12] 21/13 35/6
41/16 58/16 62/4
63/14 84/11 84/14
88/19 149/12 157/13
163/11
lawyer [9] 21/20 22/6
35/13 35/13 50/5 50/6I
52/24 52/25 85/9
lawyering [3] 116/1
203/4 203/5
lawyers [7] 20/22
48/3 85/21 92/12
122/18 155/19 168/24}
lay [1] 13/3
lead [5] 65/15 67/25
68/18 72/2 74/20
leap [1] 96/18
learn [3] 26/11
167/17 175/16
learned [7] 71/4
133/15 136/16 167/17
189/12 193/12 199/22)
learning [2] 178/8
178/13
learnt [1] 137/20
leash [3] 192/25
193/4 193/5
least [10] 12/10
55/21 86/2 95/7 95/14
98/11 115/11 126/22
131/8 168/25
leave [5] 26/25 70/9
81/18 195/7 202/6
leaving [1] 181/22
led [6] 5/21 75/13
777 113/20 126/14
131/25
Lee [4] 56/8 145/2
145/13 169/8
left [8] 30/7 31/19
32/11 44/3 44/13
127/1 161/11 172/8
left-hand [5] 30/7
31/19 32/11 44/3
44/13
Legacy [1] 8/6
legal [53] 18/21
(70) its... - legal
L
legal... [52] 18/23
19/1 19/14 19/23 20/4)
20/10 20/13 20/18
21/1 21/25 22/14
22/17 24/2 24/11
25/13 29/5 34/22 35/6
37/9 38/18 39/20
42/21 43/15 45/15
46/9 47/10 47/11
47/12 47/20 48/1
48/25 49/14 52/19
53/3 53/6 53/8 53/17
57/22 57/23 61/18
84/21 84/24 85/1
92/10 92/14 93/1
103/20 116/4 119/11
148/14 155/10 163/1
Legally [1] 34/21
legislation [1] 90/25
legitimate [1] 199/20
length [2] 11/11
89/21
lengthy [1] 176/14
lens [1] 99/25
Lesley [4] 66/13
72/12 73/18 75/3
less [12] 100/3
100/22 101/15 122/16}
134/8 136/22 142/10
147/2 156/23 165/10
165/11 196/3
lessons [2] 178/8
178/13
let [8] 92/7 131/4
190/22 192/18 192/25)
193/4 193/5 203/20
let's [12] 39/3 44/1
75/21 76/4 81/24 94/9
98/14 100/11 124/22
141/22 160/3 180/6
letter [10] 38/24
40/18 40/25 41/21
41/22 42/7 42/8 127/9I
136/3 136/7
letters [3] 25/11
142/20 143/4
Letwin [1] 138/15
level [17] 7/20 9/1
22/10 69/16 69/24
70/11 75/14 78/19
82/19 102/4 111/23
114/19 134/10 135/3
145/19 181/9 196/1
levels [1] 137/10
levied [1] 116/15
liaison [2] 64/18
76/13
licences [1] 141/19
life [2] 131/14 186/12
life-changing [1]
131/14
light [4] 35/15 47/6
67/6 94/17
like [52] 2/11 12/4
30/9 40/18 46/8 52/3
55/18 60/7 69/18 73/6)
81/16 91/12 91/18
100/15 100/21 101/14)
109/17 109/21 114/17)
117/14 119/18 119/25)
120/7 127/18 127/19
128/9 134/19 142/7
142/13 147/2 147/9
155/23 156/20 160/22)
161/22 161/25 167/12)
167/23 168/5 172/20
174/12 179/12 184/17)
184/22 185/1 192/4
192/16 194/1 194/15
196/20 197/2 199/20
likelihood [1] 130/21
likely [8] 30/22 37/21
69/12 95/7 97/14
97/16 128/1 190/1
limit [2] 182/6 182/13
limitation [2] 43/18
53/5
limitations [1] 183/12)
limited [7] 3/15 3/15
5/17 22/11 37/11 55/4
111/20
line [7] 66/25 82/17
90/1 135/15 142/20
166/17 203/9
lines [9] 8/21 32/22
101/9 114/5 146/25
159/10 159/13 193/7
198/18
link [3] 27/22 53/16
101/24
linkages [1] 141/13
Linnell [3] 137/19
179/8 179/9
list [3] 27/25 31/12
31/16
listed [3] 4/8 5/22
76/8
listened [1] 121/9
listening [2] 23/19
172/12
listing [2] 27/24 28/3
literally [1] 146/9
little [17] 2/3 79/4
89/2 89/21 91/25
93/24 94/6 121/21
131/22 147/4 148/6
149/2 153/17 179/16
184/5 186/21 194/23
live [3] 51/25 52/14
186/7
living [1] 122/8
Lloyd's [1] 3/3
Lloyds [2] 187/6
188/1
load [1] 157/15
local [4] 120/2
locally [2] 21/7 21/8
locate [3] 68/25
118/8 153/8
location [1] 21/10
lock [1] 141/22
log [1] 66/4
logs [2] 42/13 56/15
London [3] 3/4 53/7
122/9
long [9] 1/15 1/16
22/17 109/14 109/14
183/6 197/11 200/13
204/2
longer [8] 66/9 92/10
116/25 117/4 120/2
177/24 185/24 191/6
look [66] 4/25 6/13
6/14 7/8 22/12 26/5
30/3 31/19 32/9 32/11
33/16 33/23 34/18
34/19 34/20 39/3
41/18 44/1 44/2 44/13)
46/8 47/18 53/8 55/15
60/2 61/1 61/8 63/25
65/12 68/13 69/3 76/4
79/5 81/7 92/2 95/23
104/23 105/1 106/19
109/15 110/13 116/2
123/19 123/21 124/22
129/25 130/4 133/23
134/4 134/20 135/23
137/12 141/13 146/16
151/16 161/14 161/17
173/5 173/6 183/11
187/6 187/10 188/10
192/11 192/24 193/10
looked [24] 8/17 29/6
36/5 36/18 39/10
49/11 62/3 116/10
137/2 151/24 157/4
157/16 163/16 164/4
169/8 170/10 170/13
170/22 173/4 189/23
191/14 191/19 192/12
199/20
looking [34] 8/25
9/21 15/12 17/12 24/3
31/23 46/12 46/15
51/4 52/9 55/10 55/14
58/12 59/4 59/15
59/21 59/23 63/21
64/9 64/12 68/7 83/3
85/22 86/2 86/8 97/22
106/4 106/10 116/11
134/21 135/4 183/17
183/20 197/9
looks [4] 63/23
100/14 161/22 167/12
loose [1] 114/24
Lord [4] 92/5 160/3
202/2 202/5
Lord Arbuthnot [3]
160/3 202/2 202/5
Lord Arbuthnot's [1]
92/5
loss [13] 17/18 94/21
95/11 98/18 99/2
103/10 149/16 149/18
149/25 150/2 189/6
190/12 195/2
losses [7] 37/25 38/5
95/17 97/15 97/18
104/3 201/13
lost [2] 86/22 120/14
lot [14] 47/14 86/10
108/11 121/22 121/24}
121/25 131/9 131/25
163/4 170/19 184/9
186/12 186/12 195/16
lots [1] 128/24
Lottery [3] 197/5
197/14 198/1
loud [1] 159/2
lousy [1] 114/11
lovely [4] 203/10
lower [1] 201/15
LPP [3] 42/20 42/22
42/25
lucky [1] 142/11
ludicrous [2] 142/16
162/13
ludicrously [1] 92/9
Lyons [9] 57/5 60/4
66/13 72/12 73/18
75/2 81/9 134/19
134/25
M018 [1] 173/8
M035 [6] 30/8 31/20
31/24 32/4 32/19
35/21
machine [1] 159/18
machines [2] 120/4
120/5
MacLeod [2] 41/25
172/8
mad [1] 164/19
made [53] 10/7 12/14
16/8 24/6 31/5 37/11
38/8 43/19 45/4 53/14
57/24 59/11 66/16
66/18 67/8 69/13
69/23 75/9 75/14 85/4,
88/9 89/5 96/24
109/13 110/2 110/24
112/23 120/23 120/24}
121/11 122/9 129/7
130/6 130/17 135/4
137/14 140/10 143/20
150/9 163/22 163/23
164/21 168/6 168/19
169/22 172/18 180/14
186/18 188/8 197/8
199/24 200/16 202/8
Mail [4] 20/3 20/4
185/2 190/4
main [15] 11/6 15/18
19/7 21/24 22/2 42/8
58/2 62/25 64/18 78/6I
123/5 124/14 125/7
147/5 172/7
maintained [1] 20/8
major [10] 54/16
54/18 66/7 75/20
144/10 201/21 201/22)
202/23 202/24 203/2
make [22] 2/6 8/11
17/24 17/24 57/25
63/1 75/20 80/9 91/16
96/18 99/21 109/17
148/16 151/5 166/24
175/10 175/19 178/18)
179/18 181/24 185/17
202/21
making [10] 27/20
89/7 89/23 98/19
1419/7 122/11 175/2
204/1 204/2 204/8
managed [3] 42/17
151/22 197/2
management [10]
54/22 86/15 101/1
111/16 137/7 141/17
144/12 145/25 148/12!
175/20
manager [4] 3/3
33/14 64/17 67/1
managers [1] 142/21
mandate [1] 148/13
mangled [1] 120/3
manifested [2]
124/20 182/17
manifesting [1]
131/12
manpower [1]
148/13
mantra [1] 119/18
manual [2] 58/6
198/5
many [15] 20/7 31/4
31/22 35/9 118/22
119/8 128/7 132/7
142/8 142/10 179/9
179/10 179/21 180/15)
181/22
March [4] 35/23
39/10 42/11 173/3
Mark [3] 42/4 81/9
86/13
marked [11] 7/9 8/22
32/12 32/14 33/17
33/20 34/21 42/19
45/11 152/22 201/3
marking [1] 32/21
markings [1] 35/15
Markup [1] 78/9
massively [1] 180/4
master [1] 19/22
match [1] 31/9
material [14] 41/15
54/8 81/1 81/14 85/23
(74) legal... - material
material... [9] 116/17
131/21 134/15 143/20)
183/11 184/2 186/24
187/9 191/7
materialised [1] 86/2
materiality [9] 131/19)
186/18 186/25 187/4
187/8 187/12 187/13
188/6 188/10
materials [1] 136/1
matter [16] 37/10
72/14 73/13 90/18
94/13 106/12 119/25
128/23 132/14 134/6
140/15 141/20 155/14
156/1 158/24 180/21
matters [23] 21/13
22/1 22/8 41/16 43/12
61/12 62/11 68/23
74/8 74/24 91/14 97/3
97/10 110/25 119/25
120/5 122/2 143/8
155/25 156/7 156/24
162/20 173/1
mature [1] 82/8
maturity [1] 82/13
Maureen [2] 57/13
144/1
maximum [1] 20/21
may [62] 1/5 1/16
2/20 11/24 26/15
33/13 36/11 37/14
37/18 37/20 37/24
38/4 39/16 39/25
40/12 43/2 52/4 58/12)
59/4 59/20 59/21
59/25 61/9 61/18
61/19 62/14 77/22
93/2 93/15 95/16
96/11 96/12 96/21
97/13 97/13 100/1
107/12 109/6 109/16
113/19 116/7 120/16
124/24 125/1 133/21
137/25 141/24 144/21
145/9 161/15 161/18
162/11 163/1 163/2
164/22 175/21 187/9
187/14 187/15 187/16}
191/3 197/6
May 2013 [1] 161/15
May 2024 [1] 109/16
May’ [1] 39/14
maybe [7] 24/23 73/6
83/1 98/15 179/5
186/3 187/14
McCormack [2]
130/2 130/6
McKelvey [2] 57/14
144/1
me [76] 20/10 20/22
22/6 22/6 22/15 25/15)
38/17 48/19 49/17
65/16 65/21 65/24
66/16 66/24 68/4
68/19 68/25 69/6 70/6
70/12 71/6 72/10
72/18 74/21 75/4 75/6)
75/13 75/13 75/15
80/9 80/13 81/22
82/16 84/21 84/22
84/24 85/2 88/14
90/22 90/24 92/24
104/9 106/24 107/22
108/1 116/2 125/1
131/4 135/17 136/15
146/23 147/3 147/4
147/8 151/25 152/14
153/15 153/16 156/19)
156/25 170/24 174/19)
179/11 184/10 190/22)
191/7 192/18 192/23
194/18 198/8 198/19
198/25 199/15 200/11
201/17 204/12
mean [60] 7/19 8/8
9/17 9/17 10/8 11/18
12/22 21/2 21/17
23/15 24/3 24/21
25/15 28/12 29/3 29/3
31/5 33/1 35/7 55/4
71/17 80/4 81/1 85/6
85/13 86/16 89/3 91/8
97/25 98/10 101/20
103/25 108/11 114/23)
119/4 120/12 120/23
121/21 122/5 127/20
135/11 138/8 140/6
146/9 146/12 161/6
174/11 175/7 175/15
175/16 179/13 180/3
182/3 184/8 185/10
192/19 198/2 199/15
199/22 202/8
Meaning [2] 185/24
185/24
means [6] 15/17 40/6
77/1 104/14 127/17
189/16
meant [14] 16/9 66/8
82/10 118/11 129/13
130/2 130/3 1341/5
136/10 141/9 149/23
163/21 181/18 182/14)
meantime [1] 41/19
mechanics [1] 70/22
mechanism [1] 80/2
mediated [1] 201/20
mediation [33] 13/15
29/9 29/17 30/6 44/24
46/21 48/5 49/11
50/14 86/1 87/15
87/17 87/17 87/21
87/24 88/8 89/9 90/8
117/1 117/24 124/8
124/21 125/12 127/1
127/3 127/14 153/7
175/6 198/23 199/1
200/8 202/10 202/11
mediation's [1] 85/6
meet [1] 48/5
meeting [44] 6/22
6/24 8/16 8/18 9/5
25/22 51/7 51/9 64/3
64/13 64/14 64/20
67/20 67/22 67/23
68/2 68/23 68/24 70/3
70/18 71/12 72/4
75/25 77/7 77/18
78/11 90/13 106/25
107/5 118/6 135/8
135/12 135/15 136/9
152/5 153/6 154/1
155/15 156/2 161/22
177/24 179/12 195/10
202/2
meetings [8] 55/1
84/20 85/12 86/17
107/10 107/12 144/16
177/19
member [1] 4/2
members [3] 65/17
65/25 148/11
memo [1] 147/16
memoranda [1]
144/15
memorandum [1]
25/11
memory [2] 78/18
170/14
mention [9] 28/23
38/8 42/21 43/24 73/3)
81/22 122/15 157/3
193/10
mentioned [20]
52/18 56/16 70/18
70/23 98/15 129/11
144/2 153/6 153/9
153/24 153/25 154/20
156/16 171/18 175/7
182/3 185/7 193/6
195/23 197/5
merit [1] 103/19
merits [1] 53/16
mess [1] 170/5
messages [2] 134/17
145/19
messaging [2] 18/9
18/12
met [11] 20/21 21/17
55/6 65/14 68/15
88/14 90/15 133/11
135/1 155/24 203/9
metal [1] 25/1
method [1] 71/5
Metropolitan [1] 28/4
MI [2] 100/24 100/25
Michael [4] 67/8
79/17 118/5 118/7
mid [4] 4/15 18/19
47/21 50/10
mid-2012 [4] 4/15
18/19 47/21 50/10
Middle [2] 111/12
111/16
Middle East [2]
111/12 111/16
might [24] 6/8 20/19
69/19 84/13 85/22
97/20 112/21 118/24
120/3 129/7 135/17
135/17 135/18 135/18
147/10 147/20 148/5
150/8 154/14 172/5
176/21 189/7 192/14
195/7
million [4] 86/2
185/13 185/14 185/15)
mind [17] 18/3 20/2
20/16 20/23 22/11
49/23 53/15 67/22
86/4 89/9 97/14
123/24 126/24 160/7
160/7 176/6 190/15
minded [1] 7/5
minds [1] 160/8
minimising [1]
115/12
Minister [1] 130/18
minute [7] 28/10 64/2)
119/12 119/15 121/24,
135/12 192/18
minutes [5] 33/8 55/1
144/16 179/13 204/11
misappropriated [1]
129/8
miscarriages [13]
45/5 58/10 58/13 59/5)
59/22 60/22 61/5
61/23 62/1 62/15 88/6)
89/1 107/14
misclassified [1]
43/1
misconduct [12]
62/3 62/16 91/5
132/13 133/9 155/10
156/8 156/13 158/14
163/5 164/14 164/24
misleading [1] 18/13
mismatch [10] 22/23
23/4 25/20 25/23 27/4)
27/13 28/5 55/20 64/1
144/19
Misra [12] 23/5 23/21
24/5 26/14 26/17
27/11 106/5 106/8
169/8 170/7 170/9
170/14
missing [2] 27/22
136/4
mistake [5] 90/10
90/10 90/11 104/4
110/24
mistaken [5] 66/14
72/17 75/5 109/21
116/7
mistakes [2] 121/11
200/16
mistress [1] 187/14
mistresses [3] 93/17
183/25 189/10
misunderstood [7]
15/15 15/25 15/25
18/16 26/15 72/18
166/25
misused [1] 129/8
mixing [1] 162/7
mixture [1] 187/13
Mm [10] 111/25
123/18 131/3 161/16
163/8 163/13 176/15
176/19 177/9 180/18
Mm-hm [5] 114/25
123/18 161/16 163/13}
176/15
model [6] 77/14 86/7
86/10 87/3 187/20
188/8
modern [1] 98/1
modifications [1]
167/18
molehill [1] 27/20
moment [9] 12/14
17/11 17/12 43/21
64/10 64/21 104/9
161/9 196/6
money [14] 7/23 95/2
95/3 95/4 97/20 99/1
103/7 136/23 138/9
149/6 149/14 184/13
191/2 196/9
Moneychanger [2]
196/21 198/4
monkeys [1] 172/21
monstrous [2]
118/19 119/2
month [8] 6/21 17/14
78/19 94/18 96/13
101/5 102/1 186/3
month's [1] 183/20
monthly [2] 101/3
101/17
months [11] 7/13
38/25 53/11 87/1
98/10 115/9 161/19
179/23 186/9 186/9
186/9
more [49] 22/6 30/21
37/4 37/10 46/8 47/4
47/21 57/25 58/4 63/9)
69/12 74/11 75/2
75/13 83/5 83/24 87/2I
87/2 95/15 98/20
100/22 101/15 103/6
118/13 121/22 121/25)
124/8 128/1 133/20
137/6 146/7 147/2
151/22 157/14 157/15}
(72) material... - more
more... [14] 1614/5
166/12 166/13 170/21
171/10 171/11 174/23}
176/14 177/23 178/5
190/17 194/23 196/3
196/15
morning [12] 1/3 1/8
1/9 27/16 50/18 50/25}
108/19 136/21 161/15)
173/4 185/12 197/15
most [19] 18/22 24/6
54/5 73/11 88/15 95/7,
97/14 97/16 98/1 98/2
98/22 103/15 114/2
129/2 138/6 141/7
143/7 159/22 169/20
mostly [1] 149/22
motivating [1] 161/3
motive [1] 11/25
motor [1] 141/19
mountain [1] 27/20
move [5] 6/21 77/13
122/19 122/21 172/18}
moved [3] 21/9 85/18
95/25
moving [5] 17/9
22/21 158/23 177/1
184/4
MP [3] 61/17 148/1
162/25
MP-referred [1]
148/1
MPs [37] 6/23 7/4
7/20 9/5 9/16 10/25
12/4 12/16 12/23 13/4)
13/16 14/16 14/16
60/10 83/25 87/8
112/6 112/8 123/2
123/9 124/19 125/5
125/16 126/7 126/18
127/5 127/10 128/10
132/19 132/22 133/2
133/8 137/16 137/18
158/13 159/25 160/9
MR [170] 1/7 1/8 1/9
2/20 6/23 8/17 8/23
22/3 24/8 26/25 27/2
27/21 33/25 41/24
41/25 44/12 46/4
49/18 51/3 51/8 51/18)
60/3 60/3 61/8 61/10
61/15 62/13 67/18
69/25 71/10 71/20
72/4 74/4 76/12 78/11
78/24 79/14 80/14
80/22 81/8 81/10
81/12 82/2 82/12 83/6
83/16 92/4 93/7 93/11
93/12 93/14 93/15
94/12 94/13 96/4 96/7
97/8 99/19 102/7
102/8 102/9 102/11
102/12 102/12 102/16)
102/23 102/23 102/24}
102/24 104/9 104/10
104/11 104/13 104/15)
104/17 104/19 105/41
105/4 106/8 106/16
107/10 108/1 108/8
108/16 108/22 109/8
109/9 109/18 114/5
117/8 118/23 121/6
121/12 122/4 124/17
126/3 130/6 131/17
138/25 142/4 146/20
153/5 153/12 153/14
153/15 153/16 153/18)
154/10 155/3 156/8
157/13 157/14 158/1
158/16 161/14 161/23)
163/5 164/10 165/19
166/4 166/6 166/6
166/10 166/13 167/2
168/18 168/21 169/2
169/5 169/13 171/20
172/19 173/4 174/5
174/14 174/19 176/7
176/9 176/11 176/12
176/16 177/5 177/12
178/4 178/14 179/4
185/7 186/2 187/18
190/23 191/22 192/3
192/7 195/6 195/8
195/10 195/10 195/13)
198/13 198/17 202/17)
203/6 204/5 204/14
204/18 205/4 205/6
205/8 205/14 205/16
Mr Aujard [9] 102/7
102/9 102/23 102/24
153/12 153/15 153/16)
153/18 154/10
Mr Baker [8] 51/8
51/18 60/3 61/10
61/15 79/14 108/8
161/23
MR BEER [20] 1/7
1/9 26/25 102/8
104/11 108/22 109/8
109/18 117/8 124/17
126/3 142/4 158/1
164/10 172/19 176/16)
204/14 204/18 205/4
205/14
Mr Brander [1] 33/25
Mr Cameron [6]
102/23 102/24 131/17)
195/6 195/10 195/13
Mr Clarke [1] 105/4
Mr Henderson [48]
1/8 2/20 24/8 27/2
27/21 44/12 51/3
62/13 83/6 83/16
93/11 93/15 99/19
102/16 104/9 104/10
104/13 104/19 105/41
108/1 108/16 114/5
121/6 121/12 122/4
138/25 146/20 153/14
156/8 157/13 157/14
158/16 161/14 163/5
166/6 166/10 166/13
168/18 173/4 177/5
177/12 178/4 179/4
185/7 190/23 195/10
202/17 203/6
Mr Henderson's [1]
102/12
Mr Ismay [1] 195/8
Mr Jenkins [22]
67/18 69/25 71/10
71/20 72/4 74/4 76/12
78/11 78/24 80/22
81/8 82/12 106/8
106/16 107/10 166/4
166/6 167/2 168/21
169/2 169/5 169/13
Mr Jones [2] 174/5
174/19
Mr McCormack [1]
130/6
Mr Parker [1] 171/20
Mr Parsons [4] 94/13
96/4 96/7 97/8
Mr Rudkin [1] 118/23)
Mr Singh [2] 22/3
49/18
Mr Stein [10] 93/12
93/14 102/11 176/9
176/11 178/14 186/2
187/18 205/6 205/16
Mr Stein's [1] 192/7
Mr Warmington [25]
6/23 8/17 8/23 41/24
41/25 60/3 61/8 80/14
81/10 81/12 82/2 92/4
93/7 94/12 104/17
109/9 155/3 174/14
176/7 176/12 191/22
192/3 198/13 198/17
204/5
Mr Warmington's [1]
102/12
Mr Williams [1] 46/4
Mrs [2] 38/18 179/22
Mrs Hamilton [1]
38/18
Mrs Jeremiah [1]
179/22
Ms [20] 30/4 33/12
33/22 34/13 35/3
38/25 39/9 40/14 50/3
82/6 88/24 136/9
165/25 176/20 179/8
181/5 192/2 194/8
198/21 205/18
Ms Crichton [1]
176/20
Ms Crichton's [2]
50/3 165/25
Ms Hamilton [5]
33/22 34/13 35/3 39/9)
40/14
Ms Hamilton's [3]
30/4 33/12 38/25
Ms Harding [1] 181/5)
Ms Linnell [1] 179/8
MS PAGE [3] 192/2
194/8 205/18
Ms Perkins [1]
198/21
Ms Vennells [3] 82/6
88/24 136/9
much [44] 2/18 13/19)
16/5 20/4 26/24 29/9
44/9 47/2 47/4 47/18
50/21 55/5 59/8 59/25)
78/14 80/18 86/23
104/7 108/14 108/20
110/13 114/5 117/4
119/4 123/22 126/21
140/13 142/22 151/18}
160/16 177/21 177/22}
177/24 182/6 182/13
186/6 194/21 197/24
199/3 199/22 200/7
201/15 204/8 204/17
muddle [1] 131/22
multiple [3] 58/14
118/10 118/12
must [5] 72/17 75/4
105/24 115/7 147/9
mustard [1] 139/22
mutual [1] 94/2
my [70] 1/10 1/13
2/11 3/20 6/13 11/6
18/22 22/11 22/12
26/4 27/12 27/16
27/23 27/25 53/1
57/25 61/21 66/6
71/16 75/5 77/3 79/2
79/21 80/25 84/24
91/22 98/7 109/9
110/25 111/2 111/3
113/14 118/16 118/20}
119/14 120/16 120/23
127/6 128/11 132/12
134/7 137/6 141/9
152/21 154/11 154/17,
157/6 158/5 160/22
163/10 165/14 174/22)
175/7 176/6 179/5
179/5 180/3 190/15
193/6 195/23 196/22
197/11 198/12 199/7
199/16 199/16 199/17,
200/2 200/6 203/16
myself [10] 134/6
135/22 140/17 146/11
147/16 153/10 172/23
195/10 199/20 202/17
mysterious [1] 6/8
nail [1] 68/6
nailed [1] 152/19
naive [3] 165/14
199/15 199/19
name [8] 1/10 1/11
1/13 30/7 77/2 80/5
109/9 109/11
namely [6] 126/25
136/10 136/11 160/11
160/20 201/11
names [4] 57/12
144/1 159/9 195/5
narrative [2] 30/12
30/25
narrow [4] 103/7
126/9 126/23 164/18
narrowed [1] 128/12
narrower [8] 16/5
123/6 124/7 124/13
124/14 124/15 124/20)
125/7
narrowly [2] 124/9
164/6
nation's [1] 88/15
National [2] 185/2
190/5
nature [3] 19/25 71/9
157/6
NDA [5] 90/23 177/2
178/3 178/11 178/16
near [1] 19/11
nearly [1] 82/5
necessarily [2] 7/23
121/18
necessary [2] 10/24
103/6
need [29] 4/19 20/11
41/8 41/10 57/21 59/1
69/14 74/24 82/5
83/17 84/3 86/19
88/19 100/2 103/1
106/19 112/18 114/16)
117/2 133/5 138/22
146/4 149/14 151/14
157/11 165/24 166/3
182/23 196/15
needed [15] 10/23
18/4 18/5 48/19 49/18)
57/23 58/16 62/11
73/13 74/14 91/14
95/2 95/18 157/1
157/18
needs [4] 5/22 52/8
61/1 84/14
negative [2] 174/23
174/23
neither [5] 122/17
149/23 166/5 168/17
181/24
net [1] 189/5
network [5] 101/10
114/17 114/24 127/24I
(73) more... - network
N
network... [1] 131/6
never [25] 33/5 47/10
72/1 97/6 103/25
118/13 118/16 119/9
123/8 123/17 127/7
127/8 131/23 133/22
136/7 136/25 151/14
158/19 165/22 167/11
167/23 167/24 173/23)
183/5 202/21
nevertheless [1]
40/20
new [3] 7/15 43/23
187/23
newer [1] 128/1
newly [4] 103/16
News [1] 143/2
next [10] 18/24 33/7
38/23 41/21 51/21
55/9 61/9 77/20
145/21 154/3
Niall [1] 140/3
nice [1] 165/10
Nichola [2] 57/13
144/1
nine [1] 2/21
nine years [1] 2/21
no [104] 4/19 10/14
14/11 16/1 16/24 17/6
17/22 18/1 18/10
20/11 23/24 25/9
30/18 30/20 35/9
35/18 37/1 37/4 38/8
38/13 44/12 44/20
49/13 53/10 54/11
54/15 54/23 55/18
55/22 56/7 56/9 56/16
56/21 57/1 57/6 57/15)
59/15 59/19 63/7 66/8
70/19 71/5 72/16 79/1
79/8 79/9 80/12 81/2
82/24 83/17 84/3
86/19 89/22 90/10
90/23 92/10 101/20
103/6 112/18 120/2
126/12 128/5 132/10
137/18 138/25 140/12
140/15 142/14 143/25
144/3 144/9 144/11
144/13 144/20 144/25)
145/4 145/10 145/13
145/20 147/11 147/12)
149/2 149/15 151/10
155/24 157/22 160/16
161/5 168/8 168/22
169/4 169/19 171/18
171/22 174/12 176/23)
181/22 191/6 193/20
193/20 194/20 194/20
196/8 204/4
nobody [2] 178/19
188/4
noddy [1] 141/24
nominated [3] 51/20
61/17 162/25
non [11] 13/1 13/8
13/23 58/9 62/24
84/25 89/24 90/2
91/10 126/1 177/2
non-disclosure [8]
13/1 13/8 13/23 58/9
62/24 84/25 91/10
177/2
Non-Executive [2]
89/24 90/2
non-existence [1]
126/1
none [8] 55/24
149/19 150/6 157/20
193/17 193/19 200/14)
203/14
nonetheless [2]
37/16 63/1
nonsense’ [1] 157/18
nor [4] 148/12 149/24
166/5 181/24
normal [2] 42/21
98/21
normally [2] 38/1
141/16
north [1] 21/6
Northern [2] 14/9
14/19
not [213]
note [7] 51/9 64/10
64/13 76/5 76/7 97/1
177/10
noted [2] 21/12 40/2
notes [6] 54/13 64/2
64/15 64/20 110/25
144/7
nothing [5] 48/20
55/18 59/2 142/13
187/23
notice [1] 203/16
noticed [4] 20/25
23/3 23/13 27/9
November [1] 168/16
November 2020 [1]
168/16
now [58] 2/24 7/15
15/12 17/10 20/14
20/17 23/22 27/19
34/8 34/18 38/10
42/24 44/10 52/3 64/6
64/9 69/13 69/21
76/23 77/20 78/3
78/16 93/21 97/5 99/4
99/11 102/6 103/11
104/7 121/19 123/12
123/14 130/12 130/17)
130/18 133/20 134/15)
136/5 136/15 147/8
154/14 157/20 162/7
164/7 172/15 172/22
174/13 179/9 180/6
180/14 180/24 184/8
188/13 190/25 194/23
195/7 199/19 204/13
number [33] 4/9 5/12
19/24 22/18 24/5 30/8}
30/9 31/20 32/17
33/18 36/17 43/8
43/11 44/4 48/1 51/11
53/6 57/25 58/13 59/5
59/8 59/22 68/20
69/16 79/17 115/10
138/20 140/19 155/10}
156/9 201/16 201/17
204/12
number 1 [2] 51/11
201/16
number 12 [1] 44/4
number 2 [1] 201/17
number 5 [1] 79/17
numbered [1] 31/24
numbers [5] 52/17
58/8 86/4 202/16
202/17
(e)
obediently [1] 92/21
objective [4] 115/23
135/5 136/12 136/12
objectives [2] 4/23
5/14
obligation [1] 74/10
observation [1]
82/12
observations [4]
147/6 147/21 148/9
148/17
obtaining [1] 148/19
obvious [8] 122/7
123/13 131/8 138/20
172/11 193/7 201/24
201/24
obviously [14] 19/19
43/1 58/1 68/22 81/15)
85/11 106/25 121/9
135/11 154/4 179/14
180/19 192/20 196/24
occasional [1] 137/7
occasionally [2] 69/1
69/11
occur [5] 46/20 90/3
113/24 115/6 141/16
occurred [2] 55/5
141/10
occurrence [1]
186/20
occurring [1] 131/6
occurs [1] 188/1
October [10] 40/24
54/1 55/21 57/21 58/5
58/19 59/21 62/14
130/6 200/25
odd [5] 47/13 107/12
116/3 116/9 131/7
off [17] 45/22 46/13
48/6 58/3 105/3
117/17 135/19 151/11
153/19 158/5 158/20
161/4 173/16 181/3
192/25 193/4 193/5
offence [1] 149/10
offending [1] 45/25
offer [2] 37/17 72/10
offered [2] 77/17
177/12
office [325]
Office’ [2] 2/5 41/7
Office's [27] 16/11
30/13 31/1 31/2 36/25)
43/22 88/7 89/9 92/19)
92/22 96/14 96/15
107/1 113/16 119/19
125/11 131/19 136/11
147/22 147/25 148/3
152/15 152/23 171/15)
171/25 188/7 191/12
Office/Second [1]
77/5
Officer [2] 191/18
195/6
offices [2] 19/8
203/23
offline [1] 81/24
often [10] 22/14 31/5
65/23 70/1 70/7 70/8
88/12 137/2 137/9
148/24
oh [15] 111/3 113/25
114/2 115/19 120/20
129/20 132/16 146/19)
147/8 157/10 159/22
178/7 185/20 202/5
203/1
okay [27] 11/14
23/25 25/7 26/3 26/5
26/18 29/16 33/9
65/10 76/4 79/15
79/25 93/20 94/14
94/22 96/2 102/15
126/10 146/9 153/20
161/2 164/11 168/16
176/14 191/10 192/1
202/6
old [10] 7/15 19/4
19/17 24/9 24/15
27/18 49/1 77/15
122/10 153/18
old-fashioned [2]
19/17 24/15
Oliver [1] 138/14
omission [1] 91/1
omitted [2] 104/13
122/14
on [280]
once [3] 13/14
197/17 197/25
once-every-period
[1] 197/25
one [90] 2/18 3/24
9/17 11/7 16/16 25/24
28/1 28/24 33/1 36/3
42/1 46/13 47/15 61/2)
63/23 64/7 64/15 65/1
67/13 68/2 68/17
68/23 69/13 69/16
70/3 73/9 74/19 80/4
80/8 80/19 81/10
81/13 84/19 90/18
92/13 92/20 93/11
98/5 100/11 104/9
104/12 107/22 116/15)
116/19 118/23 119/22)
128/22 129/4 131/17
133/1 134/23 146/12
150/14 150/24 154/3
160/4 169/5 169/10
170/6 173/2 173/10
174/10 174/11 174/15)
175/12 175/17 175/17
175/18 176/13 177/19}
178/14 178/22 180/1
181/2 182/3 182/3
182/4 184/14 185/1
185/14 188/20 188/23)
188/24 191/16 196/14)
198/6 198/8 201/10
201/12 201/23
one-off [1] 46/13
one-sided [1] 191/16
ones [3] 59/10
157/16 172/7
only [29] 12/3 19/23
20/2 20/9 20/21 21/8
41/11 47/13 53/5 68/2)
90/15 93/10 96/24
105/9 109/20 116/11
128/21 134/6 137/18
137/21 155/12 169/10)
178/22 180/1 187/18
188/21 196/12 199/23}
202/20
ons [2] 197/3 197/9
onsite [1] 122/9
onto [4] 32/14 32/15
127/4 140/17
onus [1] 183/1
onwards [5] 47/21
77/11 89/11 110/23
171/13
Ooh [6] 147/8 157/25
176/23 192/18 192/18)
195/21
Oops [1] 147/13
opaque [1] 93/24
open [14] 5/12 10/6
14/12 18/23 19/6 19/7I
19/9 71/11 71/15
86/17 146/6 157/24
158/5 201/1
open-plan [1] 19/6
openness [1] 53/8
operate [2] 98/2
200/24
(74) network... - operate
[e)
operated [5] 20/1
143/10 199/1 199/12
200/9
operating [2] 21/5
90/22
operation [10] 8/11
55/12 56/19 68/22
73/12 74/13 97/22
185/19 199/4 199/10
operational [2] 56/23
145/15
operations [1] 187/9
opinion [5] 36/25
66/6 91/22 158/20
158/21
opportunity [1] 61/24I
opposed [1] 198/9
opposite [1] 131/10
option [2] 7/21 91/12
or [257]
oral [5] 4/9 74/11
108/18 169/11 204/9
orally [1] 108/9
order [8] 6/7 29/7
70/6 104/25 114/17
141/13 158/1 181/25
ordered [1] 113/10
ordinarily [3] 120/6
134/9 141/21
ordinary [1] 185/7
organ [1] 172/21
organisation [4] 5/17
20/5 20/24 141/25
organisations [2]
98/3 98/22
original [14] 33/11
33/21 40/10 43/24
44/5 45/19 118/8
123/8 125/13 127/6
178/17 179/12 181/3
182/25
originally [1] 47/20
ostensibly [1] 92/4
other [47] 11/17 16/3
28/24 35/10 39/5 41/5)
41/6 43/1 43/12 43/16)
59/10 59/10 62/16
70/3 81/13 85/5 87/23
90/18 92/17 93/22
97/23 121/16 124/12
127/7 127/10 131/12
136/20 141/18 143/15}
151/16 155/24 169/9
171/18 173/1 173/17
177/1 178/10 179/2
182/22 185/15 186/23}
189/17 189/17 190/24}
193/24 196/19 203/2
others [8] 129/8
134/19 172/5 180/17
191/8 197/6 202/15
203/24
otherwise [6] 34/23
99/21 136/3 137/3
184/10 185/9
ought [7] 62/3 74/15
106/9 129/6 153/7
166/15 189/9
our [65] 2/1 9/8 10/8
10/19 12/22 12/24
13/3 15/18 18/15 23/1
27/6 28/20 36/25 47/8
51/22 61/12 61/16
62/20 62/25 62/25
63/13 64/18 65/1
71/16 75/19 75/22
81/2 83/7 84/2 84/2
87/1 88/16 89/17
90/14 91/4 91/23
91/24 92/21 94/1
103/9 103/10 103/18
108/3 108/13 115/23
118/11 118/21 119/19)
121/7 123/5 123/7
123/11 125/6 127/4
128/4 135/4 155/20
159/18 162/20 162/24)
163/15 170/4 171/4
193/8 193/17
ourselves [5] 84/15
122/18 177/23 179/19)
204/2
out [87] 6/11 8/24
19/20 22/7 24/5 24/23
27/20 29/7 33/25
35/25 37/4 38/20 46/1
47/13 56/11 56/24
61/15 64/8 70/8 76/4
80/1 88/20 95/4 96/5
96/19 96/19 97/19
98/6 99/17 101/11
108/9 114/9 114/19
116/17 120/3 125/1
125/14 128/22 128/24)
129/12 132/20 133/3
136/4 137/4 138/16
141/20 145/7 145/16
147/22 157/16 158/2
158/10 159/2 160/6
160/10 160/16 163/17
167/9 168/13 171/3
176/20 177/23 180/24}
183/2 183/4 183/5
183/6 183/21 184/17
185/9 186/10 186/19
188/4 189/1 190/18
191/13 191/16 193/11
193/14 193/16 194/25
194/25 198/5 200/18
201/8 202/1 202/7
outcome [1] 135/13
outcomes [2] 135/6
136/13
outlet [1] 76/20
output [1] 126/21
outputs [1] 6/14
outset [10] 11/23
53/20 54/24 55/25
56/22 83/19 83/25
115/2 137/23 199/18
outside [11] 18/24
41/16 53/3 55/9 58/24
61/12 62/19 63/6
63/13 147/5 162/20
outsourcing [1] 20/7
outspoken [1] 138/6
over [32] 2/13 7/7
7/13 7/13 11/10 11/17,
13/12 14/5 20/18 25/3
36/24 39/24 46/4
46/24 48/16 61/14
64/7 80/5 88/16 91/17
101/4 101/18 136/20
146/25 147/19 151/12
152/3 153/13 154/2
159/1 179/9 179/21
overall [4] 17/13 55/5)
97/22 187/15
overheads [1]
136/22
overnight [1] 70/9
overriding [2] 2/2
91/24
oversight [4] 89/19
113/19 137/18 137/19]
overwhelming [1]
150/20
overwhelmingly [1]
148/19
owe [2] 166/22 167/3
owed [2] 91/18
169/16
Owens [1] 76/9
own [10] 19/8 20/8
36/25 79/21 150/1
159/6 185/4 188/5
189/6 199/17
owned [2] 89/19
188/20
owners [2] 188/21
193/14
Oxford [1] 16/2
P
pace [1] 116/20
pack [1] 40/4
packet [1] 85/24
page [103] 1/17 1/22
2/13 2/13 7/7 8/15
8/21 10/17 14/23
17/10 22/19 22/20
22/20 23/11 23/11
27/3 30/14 30/15
31/11 32/23 33/12
33/16 33/20 33/23
34/18 34/19 34/19
34/20 36/3 36/8 39/4
44/1 44/2 48/9 48/10
48/16 57/17 59/24
60/2 60/6 61/9 63/25
64/7 65/13 65/13
68/13 79/13 81/12
82/7 84/18 84/18 87/4,
88/1 89/12 94/5 94/6
95/20 95/22 95/24
96/1 99/6 100/9
100/12 102/10 102/22)
105/2 105/2 109/17
109/19 109/22 109/23
110/8 117/21 117/24
117/24 119/10 121/12)
122/23 122/23 123/21
124/25 125/2 130/9
132/6 133/15 137/11
137/12 155/4 155/6
159/1 161/17 161/24
162/17 162/18 166/16}
166/16 173/13 180/12)
188/16 192/2 192/13
194/8 205/18
page 1 [4] 34/19 61/9
100/9 162/17
page 11 [1] 81/12
page 12 [2] 48/9
110/8
page 13 [2] 65/13
65/13
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page 16 [1] 57/17
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page 18 [2] 117/21
117/24
page 2 [8] 8/21 30/14
59/24 60/2 63/25
95/24 99/6 180/12
page 20 [2] 109/17
109/19
page 21 [2] 87/4
155/4
page 25 [4] 22/19
22/20 23/11 27/3
page 26 [1] 17/10
page 28 [5] 84/18
122/23 122/23 124/25}
125/2
page 3 [7] 30/15
68/13 94/5 96/1
102/10 102/22 130/9
page 4 [2] 33/23 94/6
page 49 [2] 166/16
166/16
page 53 [1] 88/1
page 54 [1] 109/23
page 58 [1] 89/12
page 59 [1] 1/22
page 6 [2] 36/8 79/13
page 60 [2] 1/17 2/13
page 7 [2] 44/1
188/16
page 8 [7] 10/17
31/11 32/23 44/2
123/21 132/6 173/13
page 9 [3] 33/12
137/11 137/12
pages [6] 1/16 35/24
79/10 109/14 109/14
198/8
paid [8] 12/24 13/18
104/3 138/17 148/25
179/17 180/4 191/2
pains [1] 130/12
Palmer [2] 57/13
144/2
paper [11] 13/6 19/18)
19/21 19/21 24/21
24/22 94/14 99/9
99/11 170/13 183/17
paragraph [69] 1/22
2/7 4/20 5/10 10/17
10/18 11/4 14/23
17/10 20/12 20/25
22/21 27/2 33/24 34/2I
36/9 39/12 39/14 40/3
48/9 48/10 57/17
57/18 63/25 65/12
65/13 68/14 69/5
76/17 77/11 77/20
83/17 84/4 84/17 87/5I
88/2 89/13 102/25
112/19 117/20 121/13)
122/22 123/21 125/2
129/7 137/12 138/5
155/6 158/23 166/16
171/3 172/25 173/14
173/22 177/11 180/10}
180/11 180/12 180/24)
181/1 181/20 188/13
188/15 189/1 192/21
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194/2
paragraph 102 [1]
177/11
paragraph 106 [1]
166/16
paragraph 108 [1]
172/25
paragraph 11 [2]
188/13 188/15
paragraph 12 [1]
189/1
paragraph 14.10 [1]
63/25
paragraph 142 [1]
88/2
paragraph 159 [1]
89/13
paragraph 163 [1]
1/22
paragraph 19 [1]
137/12
paragraph 2.2 [1]
68/14
paragraph 20 [1]
138/5
paragraph 22 [2]
4/20 112/19
paragraph 23 [2]
10/17 10/18
(75) operated - paragraph 23
P
paragraph 3 [2]
180/10 180/12
paragraph 30 [1]
83/17
paragraph 36 [1]
20/12
paragraph 38 [1]
48/10
paragraph 39 [1]
48/9
paragraph 4.10 [3]
36/9 39/12 40/3
paragraph 4.11 [1]
39/14
paragraph 41 [1]
117/20
paragraph 43 [3]
65/12 65/13 77/11
paragraph 44 [1]
69/5
Paragraph 46 [1]
155/6
paragraph 5 [3]
180/24 181/1 181/20
paragraph 53 [2]
57/17 57/18
paragraph 55 [1]
14/23
paragraph 58 [2]
122/22 125/2
paragraph 71 [1]
121/13
paragraph 77 [2]
22/21 27/2
paragraph 78 [1]
17/10
Paragraph 8.1 [1]
123/21
paragraph 8.2 [1]
129/7
paragraph 88 [1]
84/17
paragraphs [7] 7/8
21/11 36/24 76/22
76/23 89/11 132/5
paragraphs 15 [1]
132/5
paragraphs 32 [1]
21/11
parcel [1] 186/17
parked [3] 59/6
181/10 182/15
Parker [1] 171/20
Parsons [8] 39/6
48/5 94/13 95/25 96/4)
96/7 97/8 99/17
part [30] 3/10 15/9
20/5 27/23 33/24 34/3
38/7 38/11 43/8 49/11
56/18 65/3 77/21 81/8
89/4 98/12 99/10
105/15 106/13 111/19
117/8 134/3 152/20
157/3 157/4 169/19
177/8 181/20 186/17
199/3
Part 2 [1] 65/3
partial [1] 44/8
participating [1]
108/17
particular [17] 12/5
24/4 32/8 35/11 39/9
73/18 82/17 94/25
94/25 97/5 104/20
113/21 133/6 144/18
148/22 185/25 198/21
particularly [8] 54/3
64/18 82/2 83/2
116/25 118/21 171/10)
178/24
parties [3] 73/4
137/14 138/2
parties' [1] 185/6
partisan [1] 166/23
partner [1] 179/22
parts [1] 29/17
party [8] 5/17 22/9
41/5 72/19 73/5 75/23
82/17 161/3
pass [1] 117/17
passage [1] 44/19
passed [2] 35/13
197/19
password [1] 37/2
passwords [1] 30/24
past [7] 56/2 56/11
74/16 100/2 101/4
101/18 145/6
paste [1] 133/18
patch [1] 178/15
patently [1] 164/5
pathetic [1] 120/14
pathway [2] 149/8
149/11
Patrick [3] 41/24
172/2 177/20
pattern [1] 31/22
Paula [19] 5/4 60/6
81/9 86/16 87/8 87/11
88/14 89/3 112/23
133/18 133/21 134/1
134/8 134/13 134/18
134/23 161/23 161/24)
171/12
Paula's [2] 87/22
134/18
pay [5] 95/12 99/3
138/10 138/17 188/4
paying [3] 11/9 120/1
138/13
paying-in [1] 120/1
paymaster [1] 138/4
payments [11] 22/23
23/4 25/20 25/22 27/4
28/5 55/20 64/1
144/19 199/24 202/21
pdfs [1] 58/4
PDQ [1] 185/21
Peacock [1] 151/18
PEAKs [2] 56/14
145/8
Pearce [3] 92/12
151/20 203/23
penetrating [1]
171/13
penned [1] 96/19
Penny [1] 76/10
penultimate [1] 6/3
people [25] 11/8 12/4
57/4 68/17 93/17
112/11 114/7 114/12
120/8 131/9 134/19
137/2 142/8 172/13
180/1 186/5 186/15
186/23 199/3 201/19
202/8 203/8 203/10
203/10 203/21
people’ [2] 2/3 91/25
per [3] 76/20 78/19
101/11
perception [1] 86/16
perfectly [2] 57/6
202/6
performed [2] 18/5
172/3
perhaps [15] 18/7
53/11 57/16 63/9
70/21 75/14 84/11
93/21 103/17 103/19
138/2 165/11 178/5
187/5 189/23
period [5] 98/4
101/11 154/20 186/11
197/25
periods [1] 98/9
Perkins [4] 112/24
134/24 198/21 202/2
permanently [1]
65/17
permission [1]
175/13
person [10] 73/11
82/16 106/22 132/10
140/17 167/22 183/15}
185/22 193/23 196/12)
personal [2] 74/9
147/16
persons [1] 137/22
perspective [2]
82/15 186/14
persuasive [1]
127/22
phone [2] 107/12
152/4
phrase [8] 2/2 16/23
18/10 18/14 84/1
91/24 120/22 144/15
phraseology [2]
186/19 199/23
physical [1] 69/17
physically [2] 18/20
19/2
pick [4] 22/22 79/16
88/2 191/11
picking [4] 12/14
164/23 189/20 192/3
piece [6] 124/9
124/13 124/19 133/5
147/5 183/17
pieces [2] 125/21
143/2
Pll [3] 23/9 26/14
26/17
piled [1] 25/18
pin [1] 83/5
PinICLs [2] 56/14
145/8
place [7] 30/24 70/7
104/6 118/2 155/14
191/8 201/19
placed [1] 182/7
plain [3] 64/24 73/14
132/15
plan [4] 18/23 19/6
19/7 19/9
plastic [1] 24/24
platform [1] 42/15
played [1] 136/25
plead [1] 37/19
please [83] 1/5 1/12
4/17 2/13 4/25 5/14
6/3 6/21 7/7 7/8 8/13
8/14 8/21 10/16 10/18)
14/24 21/3 22/19
22/20 30/3 30/14
31/11 32/3 32/9 33/23)
35/20 36/1 36/8 38/23
39/7 40/21 41/20 44/1
44/6 48/9 50/19 59/24
61/21 63/21 63/25
65/12 68/13 79/6
79/13 81/12 84/16
87/5 88/2 89/12 92/2
94/3 95/20 99/6 102/6)
104/23 108/23 109/6
109/11 109/15 109/22,
110/7 110/14 117/21
122/21 123/19 123/21
124/23 130/4 130/9
130/9 132/5 137/12
146/16 155/4 161/17
173/5 173/13 180/9
180/11 180/25 188/16
192/6 198/18
pm [7] 83/11 83/13
109/1 109/3 154/22
154/24 204/19
pocket [1] 188/5
POID [1] 146/25
point [66] 6/4 6/9 8/5
12/14 16/7 18/11 28/1
28/8 45/16 45/20
52/13 59/6 59/20 61/1
63/1 66/16 67/2 76/13
78/16 81/13 81/23
94/25 118/1 118/18
119/22 120/23 120/24I
122/24 123/24 124/21
126/3 126/8 126/21
127/20 128/20 130/22)
131/3 136/17 138/6
138/15 159/22 161/5
161/8 161/11 163/22
164/4 165/9 165/13
166/25 167/1 170/25
171/8 173/17 174/23
180/14 183/3 183/14
183/16 186/13 189/25)
192/3 196/24 200/9
200/19 202/12 202/19)
pointing [1] 38/20
points [5] 119/22
120/14 154/9 163/3
196/19
POIR [11] 29/20
31/17 32/7 32/8 32/10)
32/15 40/4 41/9 43/23}
44/5 47/24
POIRs [2] 200/13
203/8
POL [12] 27/5 28/14
32/4 44/10 52/23 97/4I
97/11 178/10 188/22
189/5 189/7 189/12
POL's [5] 97/2 97/9
188/18 188/23 188/24)
POL00006357 [1]
104/24
POL00021762 [1]
94/4
POL00025188 [1]
38/23
POL00029846 [1]
63/21
POL00030909 [1]
192/5
POL00034551 [2]
30/4 44/2
POL00034782 [1]
44/1
POL00040805 [2]
102/10 102/10
POL00063517 [1]
35/20
POL00065542 [1]
41/21
POL00091426 [1]
68/9
POL00096575 [1]
4/25
POL00099063 [1]
123/20
POL00102280 [1]
92/2
POL00144687 [2]
59/23 161/17
POL00180779 [1]
134/21
(76) paragraph 3 - POL00180779
Pp
POL00180832 [1]
8/13
POL00181574 [1]
51/5
POL00245685 [1]
151/17
POL00344051 [1]
146/16
POL00430943 [1]
32/10
Police [1] 28/4
policy [1] 20/7
poor [7] 30/23 52/1
52/6 62/15 98/10
98/23 200/15
portrayed [1] 96/12
pose [1] 140/24
posed [3] 60/19
61/15 126/7
position [14] 7/1
41/19 57/3 57/8 58/25)
74/9 74/21 75/19
82/21 105/6 113/13
113/14 119/19 125/18)
positioning [1] 76/2
positions [1] 75/1
possession [2] 41/15I
107/16
possibility [9] 10/6
11/24 71/1 95/14
115/3 132/12 158/17
176/17 190/15
possible [10] 37/12
60/22 61/23 97/25
100/22 101/15 107/14}
158/14 166/24 184/14}
possibly [3] 5/12
10/10 132/10
post [340]
post-8 July [1] 29/10
post-firing [1] 171/19
posted [1] 181/13
posting [1] 162/15
postmaster [1]
119/23
postmasters [3]
119/14 137/25 150/10
postmasters' [2]
119/24 203/11
potential [9] 16/6
17/18 22/8 75/19 87/3
88/5 89/1 101/12
188/21
potentially [7] 9/18
58/8 78/7 88/10
121/17 143/15 158/15}
pounced [1] 129/16
pounds [2] 98/8
104/1
PowerPoint [5] 132/7
132/9 133/17 133/19
135/20
PR [3] 86/9 86/10
86/14
practical [1] 52/12
practically [1] 155/23)
practice [4] 6/15 98/1
98/10 98/22
practices [1] 17/19
practitioner [2] 21/20)
21/22
pre [3] 31/20 182/25
184/4
pre-2006 [1] 182/25
pre-fixed [1] 31/20
pre-IMPACT [1]
184/4
precipitated [1]
160/23
precise [2] 28/19
169/7
precisely [5] 22/18
23/16 23/24 27/15
87/14
precision [1] 68/6
preferred [1] 72/7
preliminary [6] 18/4
67/23 128/4 128/8
129/1 164/13
premise [1] 42/8
premises [1] 118/25
Premium [1] 143/5
prepare [1] 104/25
prepared [13] 4/21
5/9 25/25 33/11 35/8
35/12 38/25 56/5
144/23 145/2 145/6
147/7 201/7
preparing [2] 37/5
203/8
preposterous [1]
159/3
prescient [3] 167/8
167/9 168/2
presence [1] 118/24
present [5] 40/3 51/8
76/8 144/14 156/5
presented [1] 135/21
preserve [1] 57/23
press [1] 17/4
pressed [3] 83/5
175/19 196/11
pressing [1] 59/7
pressure [5] 37/18
37/24 132/19 178/25
182/20
presumably [1]
177/14
pretty [18] 5/7 80/18
116/1 120/13 121/8
122/7 123/12 129/23
134/16 136/23 146/24)
147/17 156/25 192/12)
192/19 199/19 202/16)
203/16
prevent [2] 45/16
87/20
previous [3] 19/4
21/18 56/17
previously [8] 1/14
28/8 67/1 99/14
103/14 105/18 108/7
133/16
primarily [1] 38/4
primary [6] 132/19
133/8 133/12 135/5
136/12 158/12
principal [5] 73/9
137/24 138/3 172/3
201/25
principally [5] 13/7
14/11 57/4 124/20
137/6
principle [1] 197/10
print [1] 19/20
printed [1] 32/14
printing [1] 95/3
printouts [2] 34/4
36/20
prior [4] 3/2 27/23
41/6 119/10
priority [1] 86/20
private [1] 88/22
privilege [8] 34/22
39/21 39/21 39/24
41/2 45/15 46/4 46/9
privileged [6] 34/22
34/23 40/17 41/2
45/11 45/20
probable [3] 155/9
164/13 164/24
probably [42] 7/22
13/6 18/13 20/17
20/21 21/4 21/7 62/25
64/3 67/21 69/24
71/24 72/7 74/18
82/25 86/25 89/25
90/12 91/22 100/15
100/17 115/8 121/6
121/25 126/5 126/11
129/12 130/13 131/3
131/22 135/14 136/16}
136/17 146/13 157/7
161/6 164/5 166/12
174/21 195/7 203/6
203/17
problem [17] 12/20
25/23 27/13 47/13
81/18 89/8 138/7
150/8 178/15 178/17
183/5 184/2 186/10
187/17 196/4 197/7
203/4
Problem’ [6] 22/23
22/24 23/4 25/21 27/4
27/5
problems [16] 13/22
38/9 55/10 57/7 69/2
69/11 74/23 113/16
116/19 126/1 128/6
132/23 140/24 151/5
151/6 198/1
procedure [6] 41/16
62/6 62/12 63/14
88/20 122/17
procedures [1]
119/20
proceed [2] 135/25
202/4
proceeded [2] 37/16
91/4
proceeding [3] 37/23
38/3 116/21
proceedings [10]
49/20 49/21 71/23
106/18 145/7 145/11
145/13 169/6 170/3
193/25
process [11] 29/17
55/6 63/11 84/13
85/20 177/14 178/13
185/23 199/20 200/18}
203/18
processed [4]
196/19 197/15 197/16}
197/23
processes [3] 15/3
96/16 185/14
processes/accountin
g[1] 96/16
processing [2] 120/3
120/5
Procurator [1] 59/13
produce [3] 25/10
126/8 126/22
produced [16] 4/22
25/15 31/4 63/24
64/11 64/12 107/24
117/3 153/19 154/4
154/5 154/10 158/1
170/23 178/1 179/15
producing [4] 78/15
100/6 179/18 203/13
production [5] 49/10
50/14 90/7 126/14
127/12
products [2] 196/1
197/2
profession [1]
118/16
professional [13]
3/20 11/19 12/24
13/17 34/22 39/21
39/23 45/15 46/9
165/11 198/9 202/14
204/1
profit [9] 94/20 95/11
98/18 99/2 103/10
104/2 189/6 190/12
195/1
Program [1] 6/7
Programme [3]
181/4 182/18 182/21
progress [1] 22/9
progressed [1] 47/3
project [3] 3/24
64/17 184/4
projects [2] 3/22
3/24
prolonged [1] 204/11
promise [1] 183/5
promises [4] 112/20
112/23 113/2 115/5
promote [1] 86/18
prompted [1] 160/20
promptly [1] 80/25
proof [2] 149/17
183/2
proper [4] 113/6
136/2 136/3 201/13
properly [9] 42/10
98/19 104/25 169/1
169/15 179/20 188/19}
188/20 192/11
proportion [2] 101/5
102/1
proposal [13] 4/16
4/21 5/9 5/18 56/23
78/4 96/22 127/7
132/7 132/9 132/12
135/21 145/16
proposals [1] 134/21
proposed [1] 33/22
proposing [1] 101/23)
proposition [2] 103/7I
136/23
propriety [3] 45/9
73/23 170/2
prosecuted [2]
114/12 132/25
prosecution [22]
17/22 18/2 21/6 21/9
22/1 23/5 27/11 33/22I
37/14 37/17 37/20
39/17 51/22 52/22
53/14 56/11 57/10
63/10 155/25 156/21
160/2 170/17
prosecutions [28]
5/21 20/7 20/18 21/23
22/10 35/10 47/13
50/7 58/17 59/9 59/18
62/7 62/23 73/24
73/25 74/3 74/15
74/16 88/22 105/19
124/7 133/24 134/5
148/15 155/20 164/9
164/24 169/18
prosecutions/court-a
ppointed [1] 5/21
prosecutorial [12]
62/2 62/16 132/13
133/9 155/9 156/7
156/13 156/24 158/14I
163/5 163/6 164/13
prosecutors [6]
22/13 50/1 58/15
88/21 91/6 169/23
(77) POL00180832 - prosecutors
P
protected [2] 39/20
42/25
protecting [2] 47/5
86/20
protection [2] 103/15
159/18
protections [2] 90/21
90/23
protocol [2] 69/18
70/24
prove [2] 150/1
182/23
proved [2] 117/13
150/16
provide [24] 5/17
31/17 41/12 42/13
54/25 56/1 56/10
56/23 67/18 72/10
76/20 77/22 81/3
100/24 101/16 113/6
119/15 144/22 145/1
145/5 145/15 149/7
177/13 194/4
provided [24] 4/8
28/3 31/13 32/7 32/10
36/1 36/4 37/8 40/24
41/1 43/17 45/24
47/11 51/16 57/19
64/22 68/8 68/19 74/7
80/25 97/1 104/24
179/9 179/21
provides [3] 6/4
30/18 149/11
providing [6] 1/15
79/3 82/24 99/14
105/11 108/17
provision [4] 64/23
90/19 149/21 157/9
provisional [1] 150/5
proviso [1] 148/16
PT [1] 32/4
public [3] 26/10
86/15 87/22
publication [7] 17/14
17/25 18/11 28/14
122/24 140/7 161/19
published [4] 23/1
27/6 99/20 108/3
pull [3] 10/16 201/7
201/8
pulled [4] 179/6
punched [1] 24/18
purchaser [1] 114/22
pure [1] 137/8
purely [1] 29/3
purpose [8] 35/5
38/3 41/6 71/9 129/9
146/22 151/11 193/24}
purposes [8] 33/22
65/22 66/3 69/7 69/9
142/3 144/23 145/2
pursue [5] 72/14
73/13 73/19 75/17
184/22
pursued [3] 75/16
156/15 193/8
pursuing [4] 93/22
104/20 137/1 199/17
pushback [9] 115/15
115/25 118/11 118/14)
118/19 119/2 119/3
122/1 122/2
pushed [1] 63/12
pushing [3] 134/17
146/6 160/5
put [21] 2/18 19/20
25/3 37/18 37/24 52/2
53/1 75/12 81/14
102/11 115/7 122/17
135/1 157/7 176/2
176/3 178/25 182/13
194/8 198/22 200/21
puts [1] 79/11
putting [5] 22/14
98/17 126/24 136/6
198/23
qualification [2] 9/17
33/1
qualified [6] 2/21
7/19 7/24 52/8 61/18
163/1
quality [4] 81/14 82/3
122/2 135/3
queries [1] 84/6
query [2] 78/8 84/5
question [50] 35/7
42/9 54/10 60/14
60/19 61/14 61/15
61/18 61/21 94/23
96/11 96/21 100/1
101/19 102/17 103/18)
122/20 133/7 138/16
141/24 143/12 145/11
157/24 162/4 162/7
162/15 162/22 163/1
163/20 164/18 165/3
169/19 169/22 171/4
172/25 174/9 175/22
176/24 183/9 184/12
187/12 190/22 191/5
195/21 196/22 198/22)
200/3 200/6 203/2
204/3
questionable [1]
91/21
questioned [16] 1/7
93/14 104/15 107/21
109/8 176/11 192/2
198/15 205/4 205/6
205/8 205/10 205/14
205/16 205/18 205/20)
questionnaire [1]
202/13
questions [31] 1/10
22/14 43/3 61/2 61/11
71/17 79/2 80/25 81/2
93/10 93/11 93/19
93/22 103/23 107/20
109/10 126/7 128/25
142/7 162/19 174/14
174/15 174/18 176/16
178/11 192/7 194/11
198/12 198/18 199/4
204/12
quick [2] 51/9 185/16
quickly [3] 155/21
185/8 185/10
quite [33] 13/20
22/11 33/10 34/14
42/10 53/12 62/7
63/18 66/13 68/3
71/11 72/20 74/18
81/17 85/19 88/9 91/9
96/12 106/19 111/3
126/18 131/9 142/4
145/14 161/13 163/4
163/17 174/22 181/14
194/2 201/3 202/18
203/13
quote [4] 39/13
151/25 152/3 152/5
quoted [2] 40/2 89/5
R
ally [1] 187/24
raging [1] 183/24
raise [1] 195/21
raised [21] 12/8
13/24 48/17 50/11
56/18 60/21 61/5
61/11 61/22 72/12
85/25 91/6 104/5
111/24 112/8 118/18
127/10 160/25 162/19}
183/15 196/18
raising [5] 59/3 85/12
107/13 164/25 180/20
range [1] 38/10
ranking [1] 159/8
rapport [1] 174/10
rare [1] 131/13
rather [26] 8/1 9/8
15/23 16/8 19/17
19/18 26/21 38/5
67/16 67/19 75/20
82/20 100/23 101/3
101/17 136/10 137/22
138/13 150/25 154/15}
157/7 163/21 171/11
173/5 200/4 200/22
ratified [2] 92/16
155/22
raving [1] 164/19
raw [5] 77/21 77/25
78/5 101/3 101/17
re [2] 103/2 198/7
re-reverse [1] 198/7
reach [4] 91/14
117/18 150/12 184/18
reached [4] 15/4
38/10 129/1 168/20
reaches [1] 136/14
reaction [2] 119/14
134/20
read [12] 6/17 36/8
36/13 39/3 102/25
125/2 133/20 134/15
151/3 151/4 170/9
191/7
readiness [1] 161/22
reading [8] 27/2
27/12 42/20 47/18
132/15 133/15 148/21
150/3
reads [1] 30/17
ready [1] 165/21
real [4] 120/17 183/9
186/15 186/15
realise [3] 121/6
139/21 150/1
realised [18] 8/9 23/7
23/20 37/14 37/20
53/12 57/22 58/7
58/12 59/21 69/15
104/12 199/21 200/1
200/12 200/13 200/17,
200/19
realising [1] 201/6
realistic [1] 181/23
reality [1] 8/24
reallocated [1] 98/12
really [16] 16/14 54/2
82/4 103/1 107/22
116/3 117/14 117/14
123/15 128/22 147/15}
150/2 193/12 199/5
200/4 203/8
realtime [1] 197/23
reason [8] 11/6 30/22)
95/1 121/2 124/10
149/25 160/5 183/18
reasonable [2]
132/10 183/24
reasonably [1] 54/4
reasons [3] 11/4 15/4I
67/13
reassurance [1]
191/9
recalibrate [1]
157/19
recall [45] 12/6 16/10
16/13 17/4 22/18 24/4}
25/17 25/24 28/19
33/1 33/3 49/2 52/21
53/24 54/19 55/3 56/4
59/15 64/14 64/20
65/6 66/17 70/11
70/19 71/5 73/5 73/7
75/4 76/2 77/13 78/6
78/15 87/14 105/9
108/3 135/14 146/23
146/24 152/20 152/22,
153/25 155/12 156/12!
164/9 182/18
receipt [1] 141/25
receipts [5] 25/22
28/5 55/20 64/1
144/18
Receipts/Payments
[1] 64/1
receive [5] 72/13
78/5 135/20 165/21
171/16
received [7] 40/1
40/12 66/15 73/3
112/19 118/19 153/21
receiving [1] 165/8
recently [3] 2/10 20/2!
105/9
Recess [1] 60/11
recipients [1] 96/4
recognise [3] 146/18
183/8 183/9
recognised [6] 13/19
50/8 140/14 167/15
182/20 199/18
recognition [1] 38/12)
recollection [1] 26/4
recommend [2] 9/2
9/24
recommendation [2]
9/13 10/7
recommendations
[3] 151/5 154/9
178/23
recommended [3]
9/24 10/4 10/4
recompense [1]
179/16
reconcile [1] 74/25
reconciled [2] 96/14
98/4
record [6] 7/17
106/11 120/2 135/2
150/7 175/12
recorded [5] 79/7
79/8 136/11 173/11
175/18
recording [4] 130/5
130/5 174/25 176/1
recordings [2] 175/8
175/9
records [3] 56/23
76/20 145/16
recover [1] 149/11
recovery [1] 38/5
refer [7] 14/22 39/8
64/1 83/18 160/14
177/10 188/13
reference [21] 7/10
12/23 13/10 15/9 28/5)
30/9 32/20 35/25 43/7
44/9 62/20 63/6 63/13
87/21 107/25 125/19
132/8 134/4 149/1
186/17 192/22
(78) protected - reference
R
referral [1] 14/13
referred [20] 13/13
14/16 27/25 32/22
34/23 35/1 41/9 41/11
45/13 53/24 77/8 91/8)
108/13 121/23 124/1
124/9 131/18 148/1
148/2 178/18
referring [15] 6/18
11/3 21/4 25/21 26/7
35/16 49/19 64/13
64/15 132/6 135/14
142/18 157/25 160/12)
192/6
refers [2] 64/4 100/6
reflect [8] 5/8 9/4
9/15 89/14 97/3 97/10
132/21 135/8
reflected [7] 14/14
14/15 19/25 47/2 85/9)
125/24 163/7
reflection [6] 69/15
123/10 129/6 148/6
164/23 172/9
refrain [2] 63/15
92/23
refreshing [1] 82/20
refused [2] 171/6
171/24
refusing [1] 40/16
refuted [1] 155/22
regard [10] 43/18
62/8 62/20 90/24
124/2 167/17 178/13
179/11 199/19 200/15)
regarded [3] 12/22
13/2 193/22
regarding [5] 55/1
56/1 118/4 176/17
187/12
regardless [1]
115/24
regards [2] 92/11
92/12
regional [2] 20/8
111/10
regret [5] 12/15
15/15 134/6 137/15
161/5
regrettable [2] 43/18
90/24
regular [1] 46/18
regulator [1] 3/8
regulatory [1] 4/10
reimbursed [1]
191/15
relate [1] 187/7
related [4] 104/2
141/5 188/1 189/22
relates [2] 51/7 61/3
relating [6] 23/5
27/10 43/16 61/16
148/1 162/24
relation [14] 71/19
145/11 168/20 173/7
178/8 178/12 180/19
181/6 181/21 185/21
187/8 191/1 191/16
197/20
relationship [1]
89/17
relative [1] 55/3
relatively [9] 11/19
20/6 20/22 24/5 53/5
57/24 89/2 133/19
149/8
relayed [1] 153/14
release [2] 54/13
144/7
released [4] 94/20
100/4 130/13 189/13
releases [1] 17/4
relevant [17] 9/18
21/9 37/3 43/4 47/8
55/3 56/12 62/8 62/22
62/24 76/2 78/7
106/12 118/2 121/17
145/9 159/20
reliability [3] 73/23
105/6 147/17
reliable [2] 72/20
164/20
reliance [1] 50/3
relied [8] 21/13 50/8
73/24 106/17 114/23
169/12 193/23 194/6
reluctant [2] 78/22
87/25
reluctantly [1] 12/11
rely [3] 21/21 114/16
157/10
relying [5] 17/22 18/2
58/25 105/15 156/18
remain [2] 40/20
188/15
remained [4] 44/9
147/15 159/23 190/10)
remains [2] 92/23
188/17
remarks [1] 119/6
remember [22] 6/23
19/23 23/16 23/22
23/24 24/17 25/8 51/4
65/7 78/17 84/19 85/3
85/13 85/23 87/14
147/18 161/9 166/18
176/23 176/25 181/5
197/12
remembering [1]
78/3
remind [1] 57/20
remit [3] 14/21 14/24
15/12
remittances [1]
141/20
remote [15] 17/19
56/24 63/20 65/22
68/24 69/7 69/18
69/21 70/7 70/23 71/9
71/10 71/13 81/4
145/17
remotely [6] 65/25
67/12 70/15 71/21
145/18 183/19
removal [2] 181/21
182/19
remove [6] 37/17
38/7 109/21 113/19
181/16 203/18
removed [1] 44/21
reneged [2] 113/2
115/6
renumbered [1]
44/13
repaid [1] 193/13
repay [1] 37/25
repeat [1] 173/5
repeated [2] 150/12
180/17
replaced [1] 181/17
replacement [3]
181/19 182/4 182/4
replied [2] 41/22 61/8
replies [2] 61/9 61/15)
reply [7] 41/20 41/21
46/16 61/25 102/12
159/9 162/17
replying [1] 41/23
report [126] 16/17
17/15 17/25 18/3
18/15 23/1 27/7 27/13}
28/14 28/20 29/18
29/19 29/21 30/4 30/6
31/17 32/4 32/5 32/10
32/23 33/2 33/4 33/11
33/21 33/25 34/21
35/2 35/2 35/12 35/17
35/21 36/5 36/11
36/13 37/6 38/12
38/21 38/25 39/10
39/12 39/13 39/15
39/16 39/18 39/19
39/24 40/2 40/6 40/9
40/10 40/13 40/21
41/11 43/10 43/23
43/24 44/5 44/11
44/18 45/13 45/25
45/25 47/23 48/11
48/15 52/2 56/5 56/8
62/18 65/2 65/3 100/7
107/24 108/4 108/13
116/11 117/6 118/2
118/3 118/18 118/21
121/1 122/25 123/5
123/12 123/16 123/19]
123/20 123/22 124/10}
124/11 125/6 125/25
126/5 126/8 126/9
126/14 126/22 127/2
130/14 130/25 140/7
144/23 145/2 147/4
151/2 151/3 151/8
151/17 151/23 152/8
152/21 153/5 153/8
153/13 153/21 157/21
158/1 158/10 161/20
165/7 165/12 189/23
192/5 193/22 194/7
Report' [3] 39/14
42/9 43/5
reported [3] 72/21
73/17 141/5
reporting [2] 90/1
203/9
reports [36] 31/4
35/5 35/8 54/12 54/17
54/18 55/1 56/1 60/10)
63/23 65/1 66/16 68/4,
68/20 72/10 72/19
73/3 73/6 75/7 78/19
78/22 82/25 90/7
118/12 118/22 119/3
120/19 121/5 121/16
142/20 143/13 144/10}
144/16 167/14 191/8
203/12
repository [2] 54/7
142/2
represent [5] 7/23
13/7 93/16 95/16
130/3
representations [1]
43/12
representative [1]
5/20
representatives [1]
68/16
represented [1]
106/22
representing [2]
14/17 138/15
reprint [1] 162/22
request [15] 13/17
40/1 40/13 40/16 67/5)
78/8 99/25 102/13
102/24 125/15 126/13
126/23 152/6 152/9
153/17
requested [5] 43/15
81/1 96/9 100/4 118/9)
requesting [2] 67/16
121/10
requests [1] 149/21
require [1] 63/3
required [1] 179/17
requirements [1]
88/21
research [1] 27/23
researched [2] 66/24
148/14
reserve [1] 41/19
resistance [1] 118/17
resisted [1] 103/20
resolution [1] 190/25
resolutions [1] 5/21
resolve [2] 67/4
118/1
resolved [1] 98/4
resources [1] 140/10
resourcing [1]
140/24
respect [1] 180/16
respond [2] 99/22
99/25
responded [3] 40/16
159/3 159/12
response [10] 61/21
75/13 95/21 96/19
97/6 99/18 100/3
101/12 115/19 203/25}
responses [2] 165/9
202/13
responsibilities [1]
122/4
responsibility [2] 3/4
194/6
responsible [3]
143/23 149/18 150/2
rest [1] 151/3
restraints [1] 177/16
restriction [1] 178/3
restrictions [1] 182/5I
result [5] 23/6 100/3
121/5 157/8 160/19
resulted [7] 43/13
60/15 93/3 162/5
164/2 165/5 202/1
results [1] 34/1
resume [1] 108/22
retained [1] 76/19
retired [1] 139/13
retirement [1] 81/17
retrospective [1]
172/22
returnable [1] 188/20!
returned [6] 28/2
28/8 189/9 190/19
193/16 195/2
reuse [1] 18/10
reveal [1] 169/3
revealed [3] 60/25
106/1 169/25
reverse [1] 198/7
review [43] 3/11 5/12
5/18 5/23 6/1 6/16
7/13 7/20 7/24 8/6
8/11 9/9 9/21 9/25
10/5 10/9 12/1 12/3
12/8 15/18 15/19
15/20 29/21 30/5 35/2
35/17 35/21 38/21
39/9 39/12 39/15 40/6I
40/9 58/6 79/17
118/12 118/22 128/23}
132/11 132/20 133/4
155/10 157/15
reviewed [6] 31/10
84/14 148/12 149/20
(79) referral - reviewed
R
reviewed... [2]
170/12 170/23
reviewing [4] 147/23
147/25 150/20 172/11
reviews [2] 128/16
128/21
revisited [1] 27/24
revolved [1] 119/5
right [85] 2/22 3/12
3/16 4/14 4/17 8/7
9/23 10/1 15/7 15/10
18/20 19/12 21/14
21/25 25/5 26/7 26/15)
27/1 28/21 28/24
29/22 30/1 36/17 42/2
44/6 51/13 57/21
64/11 65/8 76/1 79/7
79/18 97/12 97/13
102/19 105/21 106/5
108/14 109/17 109/18)
110/15 110/16 110/18
110/22 111/2 111/3
111/6 111/8 111/14
112/1 112/25 115/2
115/22 128/3 128/13
128/18 131/6 132/2
135/3 137/10 138/7
139/4 139/7 140/22
140/23 141/3 142/20
142/21 144/4 157/14
163/12 166/8 175/21
176/5 176/16 177/14
180/8 181/5 184/8
194/2 194/21 198/24
199/5 199/9 200/6
right-hand [3] 44/6
128/3 194/2
rightfully [1] 195/2
rightly [4] 62/7 63/19
190/19 197/22
ring [1] 24/22
rise [2] 58/10 82/12
risk [4] 66/19 75/10
111/11 119/23
risks [2] 135/16
179/6
RJW261015 [1]
176/2
robust [1] 17/16
Rod [3] 41/24 99/8
100/19
Rod's [1] 100/17
Rodric [7] 39/4 39/6
99/9 100/17 151/21
172/5 203/23
role [7] 21/18 61/16
115/13 115/13 137/6
162/24 175/6
rolling [1] 94/17
Ron [15] 3/21 4/21
5/9 60/5 66/17 73/20
75/18 79/8 81/20
81/21 109/6 135/1
135/4 151/23 151/25
RONALD [3] 109/7
109/12 205/12
rooftops [1] 129/17
room [1] 183/18
root [6] 9/11 149/3
149/16 156/14 181/12)
184/1
roughly [1] 147/7
round [3] 124/13
124/18 200/25
route [2] 157/24
163/9
routine [1] 69/8
routinely [6] 65/21
69/6 106/23 149/22
175/10 175/12
Royal [4] 20/3 20/4
185/2 190/4
rubbish [1] 157/12
Rudkin [4] 67/8
118/5 118/23 128/23
Rudkin's [1] 79/18
running [2] 119/10
201/2
RUTHERFORD [3]
1/6 1/13 205/2
Ss
sacked [4] 66/20
75/11 90/15 93/25
Sadly [1] 159/17
safe [4] 17/23 18/2
195/25 196/16
safety [4] 66/7 84/6
87/10 87/12
said [90] 7/12 7/17
7/18 8/23 15/24 17/5
17/7 19/11 26/16 31/5)
44/19 45/3 47/9 49/18
49/24 55/14 68/7
69/10 70/4 75/3 75/4
78/2 81/13 84/22
84/22 96/7 98/11
98/21 100/20 114/6
116/2 116/17 118/6
118/10 118/25 121/3
121/12 121/13 124/17)
126/12 126/22 129/11
129/17 129/25 133/4
135/23 135/25 136/10)
136/21 138/9 142/11
146/9 146/12 146/23
146/24 152/7 152/7
152/18 152/18 153/2
153/11 155/15 156/1
157/10 157/12 158/24)
159/25 160/14 161/7
164/5 165/16 165/20
166/3 166/6 166/10
167/9 170/6 172/15
174/5 175/15 184/9
184/12 184/14 184/17)
187/24 196/14 198/6
202/5 202/21 202/22
sake [1] 104/18
salary [1] 182/8
Sale [2] 183/16
196/24
same [8] 8/16 44/9
60/6 69/4 145/11
161/24 187/16 190/22I
sample [5] 5/20 5/22
9/9 9/21 165/3
sanctions [1] 91/9
sat [2] 19/11 55/9
satisfied [1] 11/20
satisfy [1] 196/17
Savings [2] 185/2
190/5
saw [20] 16/4 23/23
24/8 25/19 27/15
27/17 28/11 28/13
28/16 47/19 52/18
82/14 86/6 102/18
107/2 116/13 116/14
129/21 150/12 157/23
say [105] 1/25 2/10
7/24 10/18 10/22
10/23 11/11 14/24
16/19 17/13 20/11
20/25 22/22 22/22
23/12 25/19 25/20
26/9 27/3 27/8 27/17
36/24 41/23 48/11
57/18 58/11 60/7
65/13 66/11 68/14
69/5 69/25 70/3 70/14
72/12 80/22 82/7 87/5)
88/3 89/2 89/13 89/16
90/17 91/17 91/18
92/6 94/16 98/15
99/13 99/23 113/15
115/2 115/4 116/6
117/25 120/11 122/25}
130/10 131/1 132/8
132/17 133/10 133/14
134/11 137/12 138/5
138/19 138/25 141/18}
141/21 154/14 155/7
158/20 158/23 160/22)
161/25 162/17 162/23}
163/14 163/22 163/25)
165/4 166/4 166/17
166/18 167/1 167/21
1714/5 171/10 171/22
171/24 173/13 174/3
175/2 179/2 183/23
185/18 185/25 187/6
187/25 189/11 198/1
200/23 201/4 202/24
saying [13] 8/24
44/25 63/1 85/12
98/24 105/15 119/12
121/18 132/14 143/4
152/3 159/3 180/25
says [15] 51/8 51/10
51/18 60/4 61/10
61/20 79/14 81/12
151/21 153/24 157/13}
161/23 174/1 185/3
194/10
scam [2] 198/24
199/14
scanned [1] 170/10
scanning [1] 58/3
scant [1] 148/25
scenes [2] 87/20
136/5
scheme [33] 13/15
29/9 29/17 30/6 44/24,
46/21 48/5 49/11
50/14 88/8 88/9 88/11
89/18 90/8 117/1
117/25 124/8 124/21
125/12 127/1 127/3
127/14 175/6 198/24
199/1 199/1 199/4
199/6 199/10 199/12
200/8 202/10 202/11
schemes [1] 200/23
scope [8] 5/15 11/10
41/17 43/19 61/12
123/8 123/16 162/20
scores [2] 119/22
142/14
Scotland [3] 14/9
14/19 59/14
Scott's [1] 147/1
Scottish [2] 59/16
59/17
scraps [1] 121/9
screen [5] 5/1 10/17
102/21 117/21 180/11
scroll [22] 5/14 7/7
8/13 8/14 10/18 30/12,
31/11 32/3 33/10
33/12 35/23 36/1 36/8
44/3 44/6 60/2 76/22
94/6 105/2 130/9
161/17 162/22
scrolling [2] 6/3
30/14
scrutiny [1] 89/22
search [3] 118/7
127/22 135/16
searchable [3] 58/4
141/18 170/11
second [110] 3/2
3/14 3/15 4/14 4/14
5/17 6/4 6/11 10/4
11/13 11/16 11/23
12/15 12/17 12/21
13/9 14/6 17/24 18/1
29/18 29/21 31/13
31/17 32/19 32/25
33/23 34/2 34/3 39/3
42/10 43/6 43/11 51/9
51/24 59/4 60/7 62/6
63/23 64/13 64/16
66/19 75/10 76/17
77/5 78/5 78/13 81/7
83/7 83/19 85/10 88/5I
88/25 89/25 90/4
90/11 91/12 92/6
92/20 94/14 99/9
99/11 100/6 102/25
103/6 107/24 109/14
110/6 111/20 113/9
115/13 115/13 116/15}
121/16 123/1 123/15
125/4 126/16 132/3
133/22 134/3 134/7
134/10 136/13 136/20)
137/13 137/15 137/17
137/20 148/2 153/21
154/9 155/16 158/20
158/21 161/25 166/16)
167/16 177/3 180/8
180/17 184/16 188/13}
192/20 192/20 192/22!
193/3 193/6 194/3
195/23 201/23
section [1] 130/10
Security [20] 32/4
32/5 32/9 33/11 33/21
33/21 39/16 39/18
39/24 40/2 40/13
40/21 43/24 44/4
44/10 44/11 44/18
45/25 48/11 48/14
see [106] 1/3 5/3
6/17 7/4 8/15 8/19
8/22 19/9 19/15 20/19
23/25 25/13 28/4
28/12 30/4 30/11
31/12 31/24 32/3
32/12 32/21 33/13
33/16 34/2 34/21
35/19 35/23 35/24
36/16 38/23 39/4
41/20 44/4 44/7 47/6
48/12 50/25 52/3
54/18 61/21 62/17
64/14 64/20 64/21
67/14 68/10 75/21
76/8 76/17 79/4 79/9
83/14 94/7 94/10
95/20 95/22 95/23
95/24 95/24 96/1
96/20 97/7 99/4 99/6
100/9 100/10 100/20
102/22 103/1 103/19
105/3 105/8 107/23
109/4 119/16 126/24
131/3 134/15 142/4
149/14 151/1 151/14
152/7 153/5 153/12
154/6 154/25 162/7
162/17 163/7 163/11
171/12 171/21 172/19}
175/22 175/25 176/3
182/2 183/11 191/19
192/9 192/18 193/18
201/17 202/13 202/15
(80) reviewed... - see
Ss
seeing [5] 23/6 28/20
105/9 129/21 182/15
seek [8] 35/6 45/16
47/1 83/20 84/8 85/16)
111/23 120/18
seeking [6] 96/23
115/23 118/23 127/23
175/13 180/15
seem [5] 19/23 48/13
126/21 127/19 149/2
Seema [11] 23/5
23/21 24/4 26/16
27/11 106/5 106/8
169/8 170/7 170/9
170/14
seemed [10] 20/22
22/11 49/25 88/11
117/10 120/7 121/2
127/18 127/22 135/24}
seemingly [3] 165/2
172/14 191/9
seems [6] 40/12
40/18 69/8 123/12
149/5 187/4
seen [22] 5/5 5/8
6/17 44/23 46/15
50/13 67/23 76/6 76/6
103/11 115/10 119/9
132/7 133/16 134/16
134/22 148/10 166/21
167/2 167/14 168/17
168/18
select [3] 5/20 89/6
173/2
selectively [2] 6/6
6/12
self [1] 94/5
sell [1] 196/1
send [2] 100/19
108/9
sending [2] 29/18
134/23
senior [7] 19/7 57/3
68/15 86/14 112/10
148/12 198/20
sensation [1] 83/1
sense [12] 50/5
52/22 53/25 81/16
114/14 122/9 125/13
135/11 167/12 175/8
193/5 200/4
sensible [1] 147/3
sensitive [2] 96/10
96/24
sensitively [1] 13/21
sent [12] 32/24 58/3
65/7 68/4 97/6 108/11
120/3 152/21 153/9
153/13 153/23 173/3
sentence [11] 23/11
26/9 26/18 38/1 40/5
92/6 109/18 109/19
118/17 125/3 132/21
sentences [1] 119/3
separate [3] 13/15
61/2 187/21
September [29] 26/6
26/6 51/3 51/8 51/14
52/5 54/1 55/21 57/21
65/14 68/11 68/15
68/23 71/7 71/11
76/16 77/7 79/11
107/5 107/6 110/23
155/15 160/11 160/19
161/12 163/4 164/12
164/25 168/24
September '66 [1]
110/23
September 2012 [3]
155/15 160/19 164/25)
September 2013 [1]
161/12
September/October
[3] 54/1 55/21 57/21
sequence [5] 28/12
28/18 28/19 46/11
200/22
sequencing [1] 27/1
sequentially [4]
31/24
series [2] 141/25
169/13
serious [3] 159/21
159/22 168/25
seriously [3] 83/2
142/10 181/14
seriousness [1]
155/9
served [3] 2/20
151/10 167/10
service [6] 54/21
59/13 77/21 78/19
142/5 144/12
services [4] 3/8 3/14
3/20 111/20
session [1] 105/1
set [19] 12/23 13/10
13/15 44/24 56/11
56/24 64/7 88/20 96/4
98/6 145/7 145/16
1714/3 180/24 189/1
192/13 192/19 193/1
193/1
sets [3] 61/15 96/19
101/11
setting [3] 33/25
35/25 108/9
settle [2] 181/17
182/5
seven [2] 41/18
155/12
severe [1] 177/16
Sewell [4] 66/13
72/13 73/18 75/3
shall [3] 41/2 108/22
187/25
sham [1] 200/1
shambolically [1]
19/16
share [6] 58/19 58/22)
115/23 125/14 157/1
158/6
shared [9] 46/25
66/12 83/21 84/7
85/16 103/17 115/22
152/14 152/18
shares [1] 203/6
sharing [4] 30/24
37/2 42/16 59/12
sharply [1] 140/19
she [45] 21/18 34/15
50/5 50/6 50/8 53/3
58/24 86/17 87/15
88/4 88/14 89/3
134/16 135/17 135/18
136/10 136/10 136/17I
146/3 146/3 146/7
146/12 146/13 146/14
146/24 147/19 151/11
151/21 152/18 156/1
158/24 158/24 160/14
161/11 166/3 166/25
179/11 179/13 179/17I
179/17 179/20 179/21
180/3 186/10 202/3
she'd [2] 21/21
147/18
she's [3] 135/14
180/1 196/12
shed [1] 67/6
shocked [1] 133/20
short [8] 50/23 83/12
96/19 98/4 109/2
133/6 154/23 204/3
shortages [1] 6/8
shortchanged [2]
190/2 190/6
shortfall [14] 30/20
30/22 97/20 143/23
149/4 182/10 182/17
183/19 183/21 184/14
187/25 196/6 196/7
196/11
shortfalls [7] 114/10
141/11 156/15 181/9
181/23 182/14 191/3
shorthand [1] 134/14
shortly [7] 2/19 27/13]
65/1 66/17 108/3
139/13 160/11
should [46] 10/7 18/8I
39/3 51/19 51/21 63/9
67/22 73/8 78/5 84/16
90/12 91/11 92/15
98/12 99/24 100/24
102/21 104/18 126/6
126/11 126/22 127/13
130/11 157/24 161/6
164/5 165/6 171/14
172/20 178/10 178/20}
185/24 185/25 188/9
190/6 190/8 190/19
191/25 193/22 195/2
195/3 195/13 195/15
198/17 201/20 202/9
shoulder [1] 117/16
shoulders [2] 119/24
149/19
show [2] 115/11
149/14
showed [2] 98/7
161/14
shown [5] 105/25
106/9 106/14 149/2
168/9
shows [1] 185/5
shredded [1] 120/4
shunted [1] 134/10
sic [4] 135/9 151/18
154/13 154/15
side [10] 2/18 30/7
32/11 44/3 44/6 44/13)
128/3 194/3 201/12
201/14
sided [2] 191/16
196/14
sides [1] 196/3
sight [78] 3/2 3/14
3/15 4/14 4/14 5/17
6/4 6/11 10/4 11/16
11/23 12/17 12/21
13/9 14/6 17/24 18/1
29/18 29/21 31/13
31/18 32/19 32/25
42/10 43/6 43/11 51/9)
51/24 59/4 60/8 62/6
63/24 64/13 64/17
66/19 75/10 77/5 78/5
78/13 83/19 85/10
88/5 88/25 89/25 90/4,
90/11 91/13 92/20
94/14 99/10 99/11
100/6 103/6 107/24
111/20 113/9 115/13
115/13 116/16 123/1
125/4 126/16 132/4
133/22 134/7 136/13
136/20 137/13 137/17,
137/21 148/2 153/21
155/16 162/1 167/16
177/3 180/17 184/16
Sight's [5] 12/15
121/16 123/15 134/3
137/15
sign [2] 12/25 13/5
signal [1] 192/23
signature [4] 1/20
2/14 109/25 110/8
signed [5] 13/6 39/4
105/3 119/17 177/3
significant [14] 38/15)
58/8 58/8 58/13 59/4
59/22 66/19 74/12
75/10 89/17 96/13
99/16 201/12 201/18
silly [1] 1638/4
siloed [4] 117/10
similar [4] 141/10
142/21 150/9 176/21
similarities [1]
141/23
Similarly [2] 119/21
190/4
Simon [23] 8/17 23/6
23/18 23/19 26/12
64/17 65/8 66/23 76/9
76/13 79/5 80/8
104/22 106/21 108/4
115/20 117/13 144/20)
160/21 161/15 161/18}
168/6 170/1
Simon's [1] 26/15
simple [3] 133/1
191/6 196/3
simply [9] 28/11
120/15 123/8 123/17
159/2 160/22 176/5
181/8 183/19
since [4] 55/19 55/20
149/13 204/5
sincerely [1] 91/9
Singh [14] 18/24
19/12 21/13 21/23
22/3 48/2 48/18 48/23}
49/18 50/4 50/9 55/9
58/23 145/22
single [1] 54/11
sir [44] 1/3 2/10 2/12
16/1 27/22 50/18
50/25 83/7 83/10
83/14 93/10 102/14
102/17 102/20 107/20}
107/21 108/21 109/4
116/19 129/22 154/13)
154/18 154/21 154/25)
173/1 174/21 175/7
175/24 175/25 176/9
179/10 180/20 183/14}
184/11 191/23 191/24)
198/14 198/15 199/15}
199/25 202/12 204/16)
205/10 205/20
Sir Alan [5] 16/1
129/22 179/10 183/14}
199/25
Sir Anthony [3]
116/19 180/20 184/11
Sir Wyn's [2] 102/17
173/1
sitting [7] 18/23 19/8
53/3 145/21 180/2
188/15 188/17
situation [6] 11/12
13/20 92/9 140/18
178/16 190/23
six [2] 98/9 186/9
size [9] 20/13 20/16
20/23 25/16 165/3
(81) seeing - size
Ss
size... [4] 185/18
186/20 187/5 187/6
sketched [1] 99/17
skilled [1] 7/5
skills [2] 10/24
149/21
skint [2] 2/3 91/25
skip [3] 36/24 61/14
91/17
Skipping [1] 173/22
slightly [5] 57/21
69/8 121/18 176/14
191/6
slips [1] 120/4
slow [1] 116/20
slowed [1] 117/15
slows [1] 154/18
small [16] 14/16
19/24 20/6 20/12
20/22 24/5 48/1 53/6
57/24 135/24 135/25
155/10 156/9 177/1
186/16 186/21
smiled [1] 93/21
smoking [1] 202/22
so [195] 2/4 2/11 6/9
6/17 7/19 8/15 9/18
9/23 12/9 13/2 13/14
13/16 13/19 13/24
14/18 15/20 16/14
17/4 19/2 19/10 19/14}
20/6 20/9 23/22 24/8
25/15 26/1 26/3 27/2
27/12 28/7 28/12 29/5
29/9 31/11 31/21 32/7
32/21 32/23 33/8
33/20 35/11 38/23
38/24 41/21 44/5
44/18 47/14 47/18
49/3 49/10 49/15
49/22 52/22 53/15
55/8 57/9 58/4 58/11
59/3 67/13 68/1 69/22
72/22 76/13 76/16
77/4 79/15 80/6 80/18
81/4 82/4 83/25 86/23
89/7 89/12 92/1 94/6
94/9 94/16 95/21 96/4
98/16 100/1 101/11
101/13 101/20 102/10)
102/21 106/12 107/2
107/8 108/9 108/15
108/22 111/24 115/1
116/12 117/12 119/4
120/25 121/8 121/25
122/5 122/14 122/16
123/2 125/5 125/19
126/22 126/23 127/10}
128/5 128/11 128/14
128/24 129/1 129/7
131/17 131/21 134/13)
135/25 136/3 140/6
140/22 141/16 142/6
142/22 146/5 150/6
151/12 151/13 152/7
153/15 155/20 156/2
156/23 156/25 158/8
159/15 159/23 160/6
161/11 161/13 161/19)
163/19 166/22 167/19)
168/1 168/16 170/12
170/23 173/19 174/25)
175/13 176/7 179/1
179/1 179/24 180/19
181/6 182/8 184/17
184/22 186/6 186/14
186/21 186/21 187/6
187/13 188/6 189/21
190/15 191/16 192/5
192/13 193/17 195/7
196/17 196/23 197/3
197/19 198/18 198/25)
200/6 200/21 201/1
201/4 201/7 201/15
201/17 202/23 203/21
204/8 204/13
Society [1] 4/3
software [5] 6/16 8/2
8/3 128/6 133/5
sole [1] 66/9
solely [3] 52/9 148/9
190/9
solicitors [3] 20/8
22/9 105/5
solution [3] 43/22
165/1 181/15
Solutions [2] 64/7
64/15
some [66] 4/16 5/12
6/23 9/13 10/9 15/20
19/7 27/14 28/1 28/8
28/13 45/3 52/9 52/14
53/13 55/4 57/9 57/10
67/24 70/20 73/22
78/16 81/22 85/11
89/4 91/11 91/21
93/19 93/23 98/8
103/19 108/5 111/22
116/3 117/11 119/6
119/11 121/8 130/16
130/24 131/9 132/24
133/3 137/18 147/19
151/5 151/16 158/8
158/15 159/9 161/11
164/13 173/17 174/15)
176/16 186/4 189/4
190/1 190/6 190/16
191/9 194/11 196/1
198/20 202/17 203/9
somebody [5] 73/9
74/12 82/5 135/19
165/19
somehow [2] 88/18
103/8
someone [4] 23/17
51/20 103/1 179/9
something [41]
10/25 16/14 22/22
23/14 26/21 31/25
34/16 51/6 67/1 70/17I
71/2 73/6 73/20 75/15
90/3 90/12 91/18
101/9 104/13 104/17
126/23 128/9 128/21
129/25 131/5 133/25
142/12 142/12 146/24
152/3 154/4 154/17
158/2 160/20 162/13
165/25 168/5 182/25
184/17 187/6 199/17
sometime [1] 148/7
sometimes [2]
116/17 118/13
somewhat [7] 12/11
18/13 19/16 19/25
85/8 85/14 165/8
somewhere [5] 13/13)
110/24 196/8 196/8
196/10
soon [2] 116/2
200/12
sorry [6] 3/19 8/14
110/9 147/13 204/2
204/10
sort [69] 3/22 10/9
14/14 16/13 16/15
19/25 21/7 24/16 49/6}
54/1 54/12 62/9 63/10
69/17 70/5 70/21
70/24 71/16 72/8
75/21 76/13 77/12
78/7 79/20 80/17 82/8
83/5 86/4 91/9 114/19
119/10 133/3 133/3
134/14 135/15 136/4
136/6 137/7 142/9
142/14 143/17 146/5
159/12 161/5 163/18
164/7 170/21 172/6
172/17 175/2 175/18
181/19 183/3 183/5
186/7 186/10 186/19
187/19 192/13 192/19}
192/22 192/23 193/10
194/8 194/17 194/20
200/16 201/2 202/9
sorted [1] 186/15
sorts [2] 137/10
175/8
sought [3] 84/5
158/22 160/24
sound [1] 141/24
sources [1] 194/5
speak [7] 48/18 73/9
73/11 108/10 155/12
171/19 176/7
speaking [4] 77/23
112/3 174/7 174/11
Specialist [2] 21/22
122/7
species [3] 56/13
56/14 156/13
specific [11] 28/23
43/3 61/17 65/23
119/1 149/1 152/9
162/25 191/12 191/14}
191/17
specifically [5] 87/18
106/7 143/7 168/24
189/25
specify [1] 27/15
speculate [1] 39/15
spelled [1] 129/12
spend [1] 22/17
spent [1] 18/22
sphere [1] 163/15
spoken [2] 18/9
52/10
spot [5] 79/17 128/15
128/16 128/21 128/23
spotted [5] 34/16
49/15 49/16 63/2
138/6
spouting [1] 119/13
sprigs [1] 24/23
spring [2] 24/15
24/17
spurious [1] 114/10
Square [1] 144/18
SRO05 [1] 79/16
$SL0000103 [1] 79/6
SSL0000108 [1] 81/8
$SSL0000109 [1]
173/7
$SL0000126 [1]
130/4
staff [5] 65/17 92/5
115/17 134/23 181/11
stage [31] 9/3 14/20
17/13 18/6 51/14
52/18 53/25 55/18
55/24 56/16 57/8
57/15 58/6 58/19
59/12 59/16 61/4
62/10 71/18 71/24
73/7 73/16 73/19 74/6
75/21 78/16 86/5
86/11 101/14 144/3
178/6
stages [4] 49/3 55/8
84/2 84/12
stakeholders [1]
92/17
stamps [2] 196/2
197/2
stance [1] 93/4
stand [1] 151/15
standard [1] 149/10
standing [1] 154/18
stands [1] 78/9
stark [1] 164/19
start [11] 15/10 18/18)
51/19 59/23 63/21
63/22 86/25 110/14
115/6 140/20 204/14
start-up [1] 140/20
started [10] 19/22
20/9 48/6 87/1 116/1
141/1 181/14 184/22
202/12 202/15
starting [2] 87/1
115/9
starts [1] 109/19
state [1] 4/20
statement [74] 1/15
1/18 2/11 2/15 4/7 4/8
4/19 10/16 12/13 14/5
14/23 17/9 20/11
21/11 22/20 27/25
34/8 34/9 34/14 43/21
46/3 48/9 57/16 65/11
68/7 68/9 69/4 69/10
69/13 69/25 70/14
77/11 82/23 83/17
84/3 84/17 86/19 87/4I
88/1 89/11 98/7
108/18 110/3 110/7
110/10 111/1 111/24
112/18 113/1 113/15
115/4 115/14 117/20
121/12 122/22 124/12
124/22 124/25 132/4
137/11 155/4 164/21
165/24 166/15 171/4
1475/7 177/10 178/1
178/2 180/8 180/8
188/13 193/7 195/23
statements [10]
36/19 56/10 69/23
71/19 74/7 109/13
145/6 167/19 169/10
204/9
states [1] 5/10
stature [1] 165/20
stay [1] 204/11
stealing [1] 143/24
steer [4] 87/9 87/12
88/5 88/25
steered [1] 130/16
Stein [10] 93/12
93/14 102/11 176/9
176/11 178/14 186/2
187/18 205/6 205/16
Stein's [1] 192/7
stems [1] 178/14
step [2] 57/21 62/19
stepping [1] 114/15
stick [1] 82/17
still [28] 13/3 14/2
44/10 59/7 63/1 91/14
123/9 123/23 123/24
127/1 127/11 127/21
127/21 127/21 128/2
128/24 129/4 130/21
131/21 131/22 152/22)
156/23 158/4 165/14
169/22 172/12 174/13)
176/7
(82) size... - still
Ss
stock [1] 196/3
stones [1] 114/15
stood [1] 197/23
stop [3] 30/15 36/2
120/23
stopping [8] 15/5
24/8 40/5 69/3 93/6
116/5 132/14 132/21
stored [1] 19/14
story [1] 117/2
Stoy [1] 145/1
straight [3] 80/13
80/23 147/17
straightforward [3]
10/19 11/3 11/5
straightforwardly [1]
67/19
strangely [1] 135/22
strategy [1] 113/16
stray [3] 62/21 63/13
63/14
strayed [1] 63/17
Street [6] 19/4 24/9
27/18 49/1 77/15
122/10
strength [1] 75/12
strike [3] 22/6 70/20
82/16
strong [2] 126/19
147/20
strongly [2] 84/9
203/12
struck [5] 22/6 38/17
80/13 80/22 141/2
structure [1] 14/14
struggling [1] 74/25
studiously [2] 130/14
130/22
study [2] 6/6 6/11
stuff [6] 116/3 116/9
122/6 170/12 187/23
195/9
stumps [2] 179/6
201/7
stupid [1] 136/15
stupidity [1] 200/2
style [1] 25/9
subheading [1]
180/10
subject [17] 23/8
26/10 34/22 42/19
42/24 94/13 104/12
137/24 137/24 138/3
138/3 143/11 171/7
175/11 175/11 178/19
194/24
subjects [2] 92/13
137/24
submissions [1] 6/1
submitted [2] 36/10
169/9
subpostmaster [25]
29/24 66/2 66/8 70/8
71/3 103/8 119/17
142/25 148/20 149/6
149/9 149/19 150/14
150/17 150/22 173/8
174/8 174/16 174/16
181/11 182/9 183/1
186/8 187/13 188/25
subpostmaster's [2]
69/20 182/8
subpostmasters [49]
10/21 13/17 17/21
45/1 55/11 56/18
60/16 61/7 65/24 70/2
70/17 86/1 86/21 92/7I
93/12 93/17 95/6
95/16 95/17 97/15
97/18 104/4 112/16
114/18 119/9 122/11
142/20 143/22 150/10)
162/6 162/10 164/3
165/6 175/12 177/13
179/23 181/13 181/21
182/21 182/22 183/10)
183/25 187/21 189/9
190/20 191/14 193/16)
195/3 201/12
subpostmasters' [2]
99/1 198/9
subpostmasters/mist!
resses [1] 93/17
subsequent [3]
45/24 107/10 191/19
subsequently [24]
3/7 3/14 11/22 12/10
13/22 13/25 16/23
23/3 23/13 23/15
26/19 27/9 31/9 35/1
66/12 68/19 72/11
76/6 78/17 110/22
111/4 116/18 133/15
157/2
subset [1] 20/3
substance [6] 72/24
106/15 107/17 116/24)
168/20 169/25
substantial [2] 95/9
98/6
such [14] 9/13 17/19
70/22 73/16 118/14
118/16 131/7 131/25
143/19 166/25 178/9
196/8 203/15 203/24
suffered [1] 201/12
sufficiently [1] 82/8
suffix [1] 36/17
suggest [1] 132/10
suggested [8] 62/3
76/24 99/14 99/18
159/8 159/9 164/15
165/1
suggesting [1] 96/20
suggestion [10]
55/11 57/25 73/5
77/14 159/3 160/12
160/19 163/10 165/15}
198/22
suggestions [1]
142/1
suicide [1] 142/8
suitable [2] 139/1
193/23
suitably [1] 7/4
suite [1] 55/16
suites [1] 144/5
sum [4] 157/19
summarise [1] 112/1
summarised [2]
74/14 133/17
summarising [1]
54/12
summary [5] 30/11
44/23 111/24 135/12
200/10
summer [1] 60/11
sums [6] 96/13 97/2
97/9 101/7 102/2
195/1
Sunday [1] 143/4
super [1] 179/20
superb [2] 82/8
179/10
supervising [1] 50/6
supplied [3] 191/7
198/8 198/10
supplier [1] 114/21
support [14] 3/14
10/25 15/3 30/19
37/15 37/22 38/13
79/3 87/23 111/20
149/24 177/13 179/10
179/23
supported [1] 48/14
supporting [4] 67/18
81/13 82/18 86/21
suppose [1] 165/12
sure [13] 5/7 12/21
28/10 42/13 65/2 77/1
98/19 100/2 117/23
161/11 170/18 174/21
179/18
surface [1] 191/13
surplus [1] 184/15
surpluses [1] 181/10
surprise [2] 202/16
202/18
surprised [9] 20/12
20/15 61/11 66/25
80/12 130/11 154/1
162/19 178/20
surprising [2] 22/16
85/15
Susan [51] 4/22 5/3
8/17 15/22 18/24
21/12 21/17 21/18
47/2 48/2 48/17 48/23
50/11 53/2 55/10 57/5
58/23 58/23 79/22
81/9 81/20 81/24
112/23 115/19 127/20}
133/17 134/24 136/24}
145/22 146/1 146/9
146/14 146/23 147/16
151/11 152/9 154/5
155/13 155/23 156/5
157/1 157/5 158/24
160/14 163/6 165/15
166/10 166/25 168/3
199/7 201/3
Susan's [1] 161/10
suspect [10] 6/23
11/18 46/14 152/5
159/14 174/21 175/1
175/11 190/10 203/12,
suspected [3] 155/18}
172/16 179/14
suspects [1] 96/8
suspense [51] 22/24
27/5 93/19 94/1 94/14)
94/18 95/1 95/5 95/9
97/1 97/2 97/9 97/17
97/21 97/25 98/2 98/9)
98/16 98/20 99/9
99/12 101/7 101/10
101/21 102/3 103/2
103/9 103/22 176/14
180/6 180/10 181/2
181/3 181/7 181/21
182/19 182/25 183/7
184/5 184/6 184/18
184/20 184/21 185/6
188/14 188/19 189/13
191/1 191/21 193/15
194/24
suspension [5] 60/15}
61/19 162/5 163/2
164/3
suspensions [1]
60/25
suspicion [4] 164/8
195/22 203/5 203/17
suspicions [1] 170/4
Suzanne [2] 57/13
144/1
swimming [2] 117/14
184/23
switched [2] 70/9
103/2
sworn [2] 1/6 205/2
system [50] 6/6 6/12
6/14 15/3 15/7 15/17
15/20 16/3 16/3 16/4
16/20 16/25 17/6 17/7
17/17 30/20 38/9
42/16 53/23 56/20
60/14 67/25 68/21
73/10 76/19 76/24
80/7 81/16 97/23
114/20 114/21 126/1
128/5 130/12 131/16
132/24 141/17 144/7
145/25 162/4 162/8
167/20 183/13 185/18}
191/3 195/25 196/10
196/13 196/18 196/25)
system-wide [6]
15/17 16/20 16/25
17/6 126/1 128/5
systemic [37] 15/2
15/6 15/9 15/16 15/17I
15/21 15/24 16/2 16/4I
16/9 16/12 16/22
16/23 17/6 18/10
30/21 60/14 61/3
124/14 124/16 126/1
128/6 129/13 130/19
130/20 130/25 131/1
1341/5 131/7 131/23
150/8 162/4 162/9
163/24 164/1 164/1
165/4
systemically [1]
141/15
systems [10] 7/12
9/25 10/5 96/16 166/8
166/19 183/16 196/20)
196/23 197/21
T
table [1] 98/7
tail [1] 92/24
take [29] 2/19 7/13
11/11 53/15 54/5 70/7)
78/24 79/15 81/24
83/2 83/7 84/24 90/3
91/7 94/3 94/4 102/6
146/25 147/19 151/12)
154/14 154/19 156/1
158/24 183/6 185/24
185/25 192/4 194/22
taken [13] 10/13
35/10 74/22 95/10
103/9 104/1 111/1
112/16 120/9 120/11
160/23 163/10 164/16)
taking [15] 29/7
43/20 53/17 78/11
82/21 82/24 98/25
102/4 116/25 117/3
117/18 125/16 165/1
186/3 200/13
talking [15] 25/7 55/8
69/15 69/17 70/5 87/7
1419/2 157/18 172/21
174/20 179/8 184/8
184/19 184/20 184/24)
tapes [1] 172/13
task [2] 10/24 11/7
tasks [1] 5/19
TC [2] 183/4 183/4
team [27] 18/21 32/5
32/10 33/21 35/6
38/19 44/5 44/11
44/18 45/25 51/20
65/25 70/14 92/10
92/14 103/2 103/21
(83) stock - team
T
team... [10] 104/21
120/24 141/12 142/5
148/4 148/12 150/23
172/6 199/16 201/8
team's [1] 199/17
teams [2] 93/1 203/7
tears [1] 178/20
technical [11] 6/15
22/14 68/20 70/5
70/21 71/5 72/2 78/10)
82/14 82/19 82/19
technically [1] 103/2
technology [2] 19/20
82/15
telephone [5] 75/24
76/7 89/4 107/2
108/12
tell [32] 2/9 4/7 12/13
14/5 17/9 21/11 34/8
46/3 53/21 54/7 55/16)
56/17 67/2 70/6 84/3
84/16 86/19 96/22
101/24 108/1 113/1
142/13 151/16 157/18)
159/1 165/24 169/20
172/25 173/15 177/21
177/22 201/17
telling [6] 45/22
66/17 72/25 74/13
179/5 200/11
tells [1] 151/25
ten [5] 20/21 25/17
33/8 179/13 204/11
tend [1] 139/19
tended [2] 19/20 72/8)
tennis [1] 136/25
term [11] 15/21 15/24)
16/15 72/6 72/7 78/10}
130/14 130/23 130/25)
163/24 186/25
terminal [6] 66/3
66/10 69/20 70/9 71/6
77/16
terminals [8] 65/22
66/1 66/5 68/24 69/7
69/18 70/15 197/5
termination [1] 10/8
terminology [1]
124/4
terms [32] 2/19 3/2
3/18 12/23 13/10 15/9
25/16 25/19 35/25
38/21 43/6 62/20 63/6
63/13 72/17 74/8
74/20 79/2 82/17
84/24 87/17 87/20
89/7 110/20 115/4
134/3 156/12 164/8
164/18 175/5 184/23
192/22
test [5] 6/6 6/12
59/20 189/3 196/17
testing [1] 62/13
than [44] 8/1 15/23
16/8 19/18 26/21 38/5)
46/8 54/6 59/10 67/16
75/20 75/25 83/5 85/5
95/15 98/20 100/4
100/23 101/3 101/17
103/6 104/7 117/4
121/16 122/1 122/5
122/17 127/7 129/24
133/20 134/8 137/22
138/13 148/6 150/25
156/24 161/13 166/14)
171/11 171/18 173/5
185/24 194/18 196/16)
thank [74] 1/4 1/14
2/13 2/18 4/13 5/2
10/15 12/12 14/21
18/17 26/24 28/21
28/22 30/15 31/12
34/20 36/24 42/7
50/17 50/21 51/2
63/20 65/10 70/13
71/8 77/4 83/6 83/10
83/15 93/9 102/15
102/20 104/10 104/16)
107/19 108/14 108/19)
108/21 108/25 109/5
109/13 109/22 110/6
110/13 111/22 132/2
138/19 148/8 154/12
155/2 165/17 165/23
171/1 173/7 175/21
175/24 176/9 177/22
178/14 180/5 188/16
191/22 191/23 191/24)
194/21 198/12 198/14)
198/16 204/4 204/8
204/9 204/16 204/17
204/18
thanks [1] 102/19
that [1396]
that's [64] 2/14 3/9
4/4 7/10 17/14 26/4
26/6 32/4 32/6 34/25
36/5 36/13 36/17
36/17 39/8 39/10 48/6)
49/23 68/8 70/11
70/17 79/17 83/4 83/8
87/6 90/3 94/20 94/23)
96/9 102/4 102/11
106/23 109/18 110/16)
1411/6 111/14 112/17
112/25 121/18 124/17)
128/11 128/14 131/18)
140/23 142/16 143/11
151/24 152/12 153/11
153/18 157/19 164/17)
168/10 171/7 174/9
175/4 176/2 177/15
186/17 187/24 192/9
204/2 204/4 204/5
theft [17] 5/13 34/6
34/13 36/22 37/1
37/15 37/18 37/21
37/24 38/2 38/3 38/7
38/13 44/20 45/9
48/13 155/18
their [51] 14/2 19/4
19/8 20/8 41/4 41/19
43/20 44/5 46/23
47/22 47/24 52/2
52/10 52/10 53/6
56/19 66/25 67/11
68/16 80/2 86/7 86/9
89/7 99/2 112/7
113/13 114/18 118/19}
119/9 119/24 123/3
127/11 132/24 133/8
133/12 138/1 149/21
150/1 152/6 158/13
159/6 160/1 175/13
177/25 179/24 182/23
186/22 188/2 188/4
190/12 195/1
them [51] 12/9 25/11
31/2 31/3 34/2 44/13
47/10 52/11 54/20
57/25 58/22 64/22
64/23 64/25 72/14
72/21 72/23 73/8 75/5
79/23 80/1 80/20 83/2
83/3 83/3 100/23
108/13 121/11 123/4
123/10 128/21 128/22)
133/11 142/2 149/20
157/6 164/7 165/1
167/14 172/10 175/11
177/25 181/22 185/3
185/5 185/12 193/2
198/22 200/14 203/7
203/14
theme [1] 88/2
themselves [7] 103/3
112/11 131/13 134/11
137/4 153/3 167/13
then [100] 2/21 3/8
4/13 8/13 10/20 18/18
23/2 23/13 25/3 27/8
28/8 28/13 28/16
29/21 29/24 30/8
30/11 30/12 31/2
31/20 31/25 32/16
35/20 37/7 44/5 44/23
48/23 49/15 49/20
51/23 60/9 60/12
60/17 61/8 61/14
61/14 61/20 65/11
65/20 66/21 70/13
73/20 76/22 76/22
82/6 95/21 96/1 96/12
96/19 100/6 100/8
100/20 101/8 101/11
102/1 103/9 107/5
109/22 111/13 111/19}
116/18 119/17 124/23
125/19 128/22 130/22
132/3 134/20 140/12
141/18 149/10 150/11
150/19 151/4 151/25
159/1 159/6 159/13
159/13 162/2 162/14
162/17 162/22 164/14
165/2 174/4 174/12
175/5 177/1 184/4
188/14 189/1 189/1
190/11 190/12 193/17,
194/2 195/18 196/13
197/3
theoretically [1]
181/10
theory [1] 198/2
there [177] 2/6 2/8
8/5 8/10 9/10 10/3
11/3 12/20 13/9 13/12}
14/16 15/1 15/5 15/6
15/8 15/20 16/8 16/24I
19/23 20/9 21/5 24/8
24/13 24/23 25/13
25/21 26/9 26/25 28/4,
31/12 31/15 33/4 33/5
36/2 37/14 38/11
38/12 40/5 44/4 45/5
46/25 47/14 47/25
48/20 53/5 53/15 54/7)
55/18 57/6 58/7 58/13)
59/8 61/2 61/3 62/14
66/19 69/3 71/15
73/13 73/15 73/16
74/23 75/10 77/13
77/23 78/1 78/6 78/21
80/2 81/1 87/7 89/8
89/21 90/18 91/11
93/6 93/7 93/11 95/4
95/9 95/14 96/7 96/12
96/20 98/14 99/6
100/20 102/12 102/22}
107/25 115/16 116/5
116/12 116/24 118/23}
119/2 121/8 121/19
121/21 121/21 123/22}
125/21 126/21 127/8
127/21 128/24 129/15}
130/10 130/12 130/15}
130/15 130/22 131/7
132/14 132/21 132/22}
134/14 135/15 136/5
140/7 140/10 141/22
142/13 142/14 142/15)
143/21 146/5 146/12
146/14 146/15 147/11
150/7 151/4 151/25
154/16 163/25 164/1
164/8 165/4 165/15
168/25 172/5 174/5
174/15 175/8 175/9
176/2 176/4 176/20
177/2 178/10 180/24
182/6 182/7 182/13
182/13 182/24 183/1
183/2 183/9 183/15
183/16 184/25 185/5
187/19 189/23 189/25]
190/14 190/17 190/20)
192/9 192/16 195/15
197/6 197/25 200/9
202/3
there'd [3] 78/15
133/8 177/6
there'll [1] 184/17
there's [22] 30/11
35/24 38/10 59/1 60/2!
61/2 71/1 78/1 95/22
109/16 109/18 142/12)
159/13 161/18 168/23)
177/21 178/20 184/9
187/23 192/13 195/12)
196/8
thereabouts [1]
79/12
thereafter [2] 133/21
160/11
thereby [1] 149/25
therefore [24] 15/7
19/9 21/21 38/16
40/21 42/25 50/18
61/6 64/22 94/3 94/7
95/11 96/24 100/2
105/24 128/18 134/10}
138/10 138/22 154/3
154/6 168/9 188/20
193/22
these [31] 9/23 25/11
25/14 28/11 33/10
35/5 35/7 46/12 46/16I
A7IN7 48/22 55/15
58/1 61/12 62/22
64/20 69/23 74/23
88/12 101/9 116/4
126/9 129/21 130/20
136/1 158/9 162/20
186/21 191/1 197/3
197/19
they [158] 2/17 11/4
11/20 12/5 12/7 12/10
13/4 13/7 13/25 14/2
14/11 19/19 19/19
19/20 20/1 20/2 20/6
24/15 25/15 28/15
30/10 31/5 31/7 38/11
38/14 40/18 41/18
41/19 45/4 47/4 47/5
47/5 47/13 51/12 52/1
52/2 52/4 52/12 52/19)
52/22 52/23 53/13
53/24 54/2 54/3 54/5
54/7 54/13 54/16
54/21 56/16 56/21
57/1 57/2 58/3 58/4
59/17 64/24 66/3 67/7I
72/14 72/19 72/25
73/3 73/8 73/12 75/4
75/5 75/6 78/20 79/24I
85/22 86/6 86/7 86/9
87/23 100/4 101/22
1410/5 110/12 114/8
(84) team... - they
T
they... [77] 114/10
114/11 115/22 116/1
118/10 118/10 120/1
120/21 121/10 121/14}
131/8 132/24 134/11
137/4 138/1 138/17
140/15 143/14 143/23}
144/14 144/25 149/2
149/18 150/1 158/21
159/5 159/6 159/25
160/25 167/13 169/19}
172/2 174/14 178/1
181/7 181/8 181/12
181/24 182/15 182/22)
183/11 183/12 184/2
185/9 185/11 186/7
187/7 187/22 189/8
189/21 190/11 191/11
192/24 192/24 192/24}
193/1 193/4 193/5
193/9 193/13 193/15
195/15 197/22 197/23}
198/6 198/6 198/24
198/25 200/14 201/22)
202/20 202/21 202/22
202/24 203/7 203/10
203/12
they'd [4] 119/9
175/14 175/15 191/15}
they'll [1] 194/18
they're [5] 4/7 5/22
31/24 174/2 194/18
they've [3] 44/12
44/12 100/23
thick [1] 203/16
thin [1] 95/4
thing [12] 89/2
104/12 128/2 143/6
143/7 146/5 153/18
166/1 179/7 187/18
194/20 196/8
things [31] 7/18 11/3
23/10 24/17 29/7 47/3
51/19 55/15 63/2
69/16 69/18 82/15
82/18 85/11 116/17
120/15 120/24 124/12)
135/19 139/19 141/17)
143/18 146/24 157/2
162/8 162/11 177/23
183/2 193/10 200/5
200/21
think [200] 2/24 4/2
4/14 7/10 7/19 8/16
10/6 11/6 13/13 14/14}
14/17 15/22 16/4 17/3}
18/8 18/19 19/11
19/16 21/19 24/2
25/24 26/1 27/22
27/24 31/7 34/16 42/5
46/23 47/25 48/6 51/7)
52/17 53/10 54/11
54/19 55/5 57/25 60/1
61/1 62/5 62/7 62/10
62/19 63/9 63/18
64/11 64/16 65/1 65/2
67/13 69/12 69/14
71/1 71/24 72/6 73/22
74/5 74/18 75/9 75/13)
75/19 75/23 76/5
76/14 76/15 78/18
79/4 79/7 79/8 79/20
79/21 81/24 82/10
82/24 83/24 84/9
84/12 84/13 85/18
86/6 90/10 91/4 94/1
98/6 99/24 101/20
101/23 102/18 103/17,
104/18 105/9 105/21
105/23 105/24 106/4
106/8 106/19 107/20
108/15 109/16 110/14)
110/23 110/25 114/3
115/16 116/1 117/8
125/10 126/3 127/20
128/9 128/10 128/11
128/14 128/20 129/6
129/11 129/21 129/23)
130/6 134/11 135/17
135/23 136/16 136/23)
138/14 138/14 139/13)
140/12 140/19 141/1
144/21 146/12 147/8
151/10 151/11 151/11
152/19 153/14 153/15)
153/16 157/6 157/25
158/18 158/18 160/4
160/22 161/8 161/11
161/12 162/11 163/21
164/22 164/23 165/13)
166/20 167/1 167/6
167/15 168/1 169/7
169/10 169/14 170/10;
170/19 171/22 172/5
173/10 174/17 176/9
176/13 177/24 178/1
178/10 178/14 180/1
1814/5 182/7 182/24
183/8 193/20 194/9
195/6 195/12 195/23
195/25 197/5 197/21
198/17 198/22 199/7
199/25 200/8 200/19
202/3 202/4 203/6
203/17 203/22 204/13)
thinking [1] 165/14
thinly [1] 85/1
third [8] 5/16 22/9
72/19 73/4 73/5 150/5
173/14 193/21
third-party [3] 22/9
72/19 73/5
thirdly [1] 70/13
thirds [1] 100/12
this [325]
Thomas [1] 76/10
thorny [3] 201/10
201/15 201/17
thorough [1] 190/17
thoroughly [2]
155/21 192/12
those [76] 3/18 3/19
3/24 14/9 14/10 23/10
24/6 24/17 25/18
47/15 52/17 53/1
54/12 58/20 62/10
70/16 71/3 86/4 88/21
89/12 91/6 93/10 95/7
95/15 97/17 98/3
98/11 98/12 106/11
108/12 112/23 113/2
113/23 123/1 125/4
125/24 126/7 127/17
128/12 128/17 131/14
139/9 139/9 141/12
141/22 142/14 143/17I
148/10 151/5 153/9
157/1 170/11 170/12
170/20 170/23 172/6
175/13 175/17 178/11
179/14 181/13 185/6
185/8 186/4 186/5
188/21 190/9 192/17
196/23 197/9 197/21
198/12 201/20 202/15}
203/10 203/21
though [11] 12/11
18/14 27/14 37/12
37/20 68/2 82/9
130/15 130/23 149/19}
194/24
thought [11] 26/16
77/5 79/11 85/13
129/14 130/3 131/25
147/9 156/25 160/25
163/18
thoughts [3] 113/23
158/9 171/2
thousands [3] 98/8
104/1 173/21
threads [1] 9/23
threat [5] 37/23 85/2
85/4 86/7 87/3
threatened [1] 91/8
three [19] 14/6 64/7
64/15 76/22 98/21
101/3 101/17 101/18
108/6 139/6 139/9
140/7 160/4 163/3
165/3 176/13 186/9
189/6 198/10
three days [1] 98/21
three paragraphs [1]
76/22
three-case [1] 165/3
three-year [2] 101/3
101/17
threw [1] 182/22
through [31] 12/3
24/17 25/18 35/24
46/11 50/14 79/9
80/19 86/1 86/13 89/6
89/7 93/12 99/19
99/24 101/13 118/7
118/12 127/14 131/6
134/18 138/18 143/8
171/13 172/1 189/18
192/21 200/17 203/15}
203/18 203/22
throughout [6] 8/9
12/2 13/3 46/20 53/9
79/1
thrown [1] 137/8
thus [1] 16/25
thwart [1] 172/18
tigress [1] 179/12
till [2] 138/1 196/15
Tim [1] 130/14
time [92] 3/10 5/5 6/9)
6/18 9/25 10/3 11/11
11/22 13/13 17/25
18/22 20/17 21/12
26/22 27/14 28/13
34/16 46/24 48/4 48/4)
50/10 50/18 52/5 53/7,
54/5 59/18 67/8 69/4
69/23 71/24 76/6
76/14 77/3 90/4 90/15)
94/25 101/7 102/2
102/6 103/12 104/5
104/8 105/10 105/25
106/20 106/25 107/8
108/22 113/23 114/3
115/16 116/22 117/19}
122/24 127/16 130/20}
131/2 131/4 134/22
136/1 138/12 140/6
140/11 150/16 152/23}
154/9 154/18 160/10
167/23 168/9 172/16
172/16 174/23 181/22)
181/25 184/4 184/7
185/25 186/5 186/7
196/6 197/11 199/10
199/16 199/17 199/18}
200/6 200/7 200/9
200/13 200/20 200/25)
times [5] 41/3 118/10
132/7 143/4 180/15
timing [2] 55/3
106/19
tiny [2] 164/3 186/21
tip [1] 20/20
today [10] 1/14 27/24
60/19 103/22 105/1
116/10 162/15 163/16}
171/18 177/5
today's [2] 8/18 51/9
Toddle [1] 158/5
together [8] 9/23
81/14 94/19 136/7
141/13 141/17 142/2
142/19
token [2] 199/23
202/21
told [43] 2/14 9/16
12/7 27/12 48/18
48/19 57/9 57/12
65/16 65/21 65/24
66/13 66/24 67/19
69/6 69/10 69/25
70/11 70/14 72/16
72/18 73/14 73/17
74/3 74/5 74/20 75/5
75/6 78/17 80/1 80/9
84/22 88/14 105/17
142/15 163/4 163/6
164/11 177/21 189/20)
194/12 198/25 202/19)
tomorrow [1] 204/13
too [9] 15/13 15/14
24/19 45/20 78/1
104/19 126/19 147/20)
189/19
took [13] 45/15 45/20
73/20 85/1 89/3 91/19]
104/6 120/13 120/13
155/14 191/8 201/3
201/19
top [22] 5/3 8/14 25/3)
30/5 32/11 33/16
34/18 36/3 87/5 94/6
96/1 99/7 100/10
100/11 102/22 109/19)
1414/8 115/3 137/10
162/18 166/16 188/15)
topic [2] 83/8 94/2
total [3] 101/5 102/1
169/14
totally [1] 120/4
touch' [1] 92/16
towards [7] 88/7 90/8
90/14 92/3 107/1
174/22 203/11
trading [2] 77/2
101/11
train [1] 180/3
trained [1] 72/1
training [2] 15/3
197/11
tramlines [1] 193/1
transaction [3] 76/20
149/1 186/23
transactional [1]
197/13
transactions [8]
101/6 101/22 102/2
183/20 197/14 197/16)
198/1 198/3
transcribers [1]
176/3
transcript [5] 79/6
130/5 131/21 173/6
173/11
transcripts [2]
150/21 172/12
transferred [1]
119/23
(85) they... - transferred
T
transparent [2] 135/5I
136/12
trap [1] 172/24
travelled [1] 20/5
Treasury [4] 138/8
138/12 138/15 138/18
treated [3] 2/4 89/20
92/1
tree [1] 165/21
trepidation [1]
147/20
trial [3] 23/8 68/8
68/10
trials [1] 143/22
tried [3] 91/19 121/9
182/9
trouble [1] 85/2
troubleshoot [2] 69/2!
69/11
troubleshooting [1]
69/19
trousered [2] 190/7
190/8
true [11] 2/15 12/6
105/23 110/3 110/10
118/18 149/25 153/3
193/14 195/19 197/24}
truly [3] 10/22 189/8
196/13
trumpeted [2] 17/4
129/17
trumpets [1] 168/14
trust [1] 9/8
trusted [1] 88/15
truth [10] 47/1 73/1
83/20 84/8 85/16
115/23 127/22 135/17
171/13 188/19
truth' [1] 1541/1
try [7] 33/7 121/15
125/20 178/15 183/18}
183/20 200/21
trying [7] 70/20 112/6I
113/19 117/16 119/21
149/15 183/10
tuck [1] 75/21
Tuesday [1] 1/1
turn [31] 1/17 4/13
4/19 8/13 14/21 20/11
22/19 29/8 31/11 48/8
57/16 63/20 68/13
79/13 83/18 84/3
84/16 86/19 87/4 88/1
89/12 110/6 112/18
117/20 120/3 132/5
155/3 166/15 171/2
180/6 201/4
turned [2] 114/9
167/9
turning [1] 121/8
turnover [1] 187/9
turns [2] 157/16
194/25
twigged [3] 120/15
199/25 200/16
two [45] 24/3 24/23
28/23 36/24 38/24
61/2 64/7 64/15 74/25
78/6 84/12 89/24 93/3
98/5 98/21 100/12
108/6 109/13 115/1
125/21 133/1 133/15
138/2 139/21 153/10
162/7 162/11 165/2
165/21 173/19 174/16)
175/8 177/19 186/3
186/9 190/2 195/11
199/4 201/9 201/20
201/22 202/23 202/24
203/6 204/8
two paragraphs [1]
36/24
two-thirds [1] 100/12
type [5] 46/15 46/17
78/10 156/12 181/7
types [2] 108/6 181/1
typical [1] 31/4
typically [1] 98/5
U
ulterior [1] 11/25
ultimate [1] 13/3
ultimately [4] 95/12
97/16 128/19 157/20
um [4] 12/19 76/16
134/2 192/18
umbrella [1] 184/13
unable [2] 34/5 36/21
unanswered [1]
128/24
unaware [4] 67/1
69/24 71/18 108/7
unclear [1] 92/24
unconcluded [1]
158/9
unconnected [1]
150/10
uncovered [1] 156/9
uncovering [2] 87/2
158/15
undated [1] 79/9
under [12] 5/14 21/2
74/10 78/19 84/24
90/23 92/20 100/5
113/9 124/21 149/17
184/12
underestimate [1]
86/3
underlying [9] 9/11
149/3 149/16 149/22
153/12 156/14 178/15)
184/1 194/7
undermine [1]
156/21
underscore [1] 31/25
understand [16]
27/19 54/2 55/14 78/3
83/2 94/24 132/11
172/14 181/24 184/5
186/4 187/4 189/16
189/17 193/3 197/22
understanding [6]
6/13 123/7 125/12
125/20 160/18 199/8
understatement [1]
183/24
understood [5] 63/8
70/22 71/20 80/7
183/16
undertake [1] 4/16
undertaking [2]
40/24 43/4
undertakings [1]
A7T7TN7
underway [1] 165/15
Underwood [1] 42/4
unfortunate [1] 16/15)
uninvestigated [1]
190/10
unique [2] 11/7 30/9
uniqueness [2]
187/19 188/7
unless [3] 37/21
92/16 184/10
unpacking [1] 40/5
unprecedented [1]
118/20
UNRECONCILED [1]
189/5
unreliable [1] 114/20
unresolved [4] 97/3
97/10 189/14 190/11
unrestricted [3]
112/20 115/5 155/11
unsafe [5] 61/19
133/23 134/4 163/2
197/21
unsuitable [1] 159/4
unsurprisingly [1]
124/18
untenable [1] 92/9
until [12] 37/5 48/5
50/19 83/7 117/6
140/6 154/14 160/16
179/13 199/21 204/13}
204/20
unusual [5] 11/12
13/20 117/9 120/25
131/13
unusually [1] 204/11
up [68] 4/19 5/1 8/14
10/16 12/14 14/24
20/12 22/19 22/22
25/18 39/7 44/15
44/16 44/24 46/8
57/17 68/3 79/16
79/22 81/1 81/17
83/18 84/4 84/16
86/20 88/2 89/12
95/20 95/22 99/6
102/5 102/11 112/18
116/1 117/6 117/14
117/20 117/21 127/3
128/15 132/5 137/10
139/1 140/6 140/17
140/20 143/8 145/14
151/8 155/3 163/10
164/16 164/23 165/1
165/20 166/15 169/11
180/11 181/14 184/23}
189/24 191/11 192/3
192/5 193/2 194/18
203/4 203/5
updated [2] 2/11
43/13
upfront [1] 1338/7
upon [11] 12/9 42/21
73/24 90/9 114/23
126/23 170/2 182/22
187/5 193/23 194/6
urgently [1] 157/11
URN [1] 1/16
us [114] 1/3 1/11 2/9
2/14 4/7 7/9 9/12
10/23 12/13 13/4
13/25 14/5 15/23 17/9}
21/11 22/24 23/17
24/6 27/5 34/8 37/9
37/11 37/12 40/22
42/12 46/3 47/16 48/1
48/7 48/22 51/1 51/21
57/20 57/24 58/1
59/11 63/22 64/19
65/5 67/2 74/14 80/21
81/18 82/11 83/14
84/3 84/16 86/19 87/9)
91/14 92/15 92/18
94/24 97/6 103/12
105/17 108/5 108/11
108/13 109/4 109/11
113/1 115/9 115/21
117/13 117/17 119/1
122/17 124/19 125/16}
127/6 129/18 130/16
130/24 131/5 134/9
134/13 135/2 136/8
139/21 140/12 146/7
151/16 154/1 154/25
157/10 157/17 157/18}
158/7 158/12 159/1
162/12 165/16 165/17}
165/24 166/20 168/4
169/20 170/23 172/25}
177/21 179/1 179/18
184/5 189/12 189/16
189/16 194/1 194/18
200/14 201/25 202/18
202/21 203/15
use [13] 16/11 16/17
16/22 17/12 18/15
29/14 69/8 71/12
129/13 131/23 163/24}
165/2 187/7
used [35] 15/16
15/22 17/3 19/19
24/17 37/18 37/24
41/5 58/4 65/21 69/1
69/6 69/11 70/1 71/13
72/7 77/14 95/12 99/3
105/18 118/15 118/17)
119/3 121/4 121/4
121/20 129/15 131/23)
131/24 132/1 146/13
172/9 186/25 193/23
194/7
useful [1] 58/1
user [5] 30/22 37/2
114/22 183/23 198/5
user-friendly [1]
183/23
usernames [1] 30/24
using [13] 16/2 42/16
60/13 69/18 70/23
98/15 130/14 130/23
130/24 134/14 149/12)
162/3 184/2
usual [1] 30/25
usually [1] 204/5
utter [1] 170/5
Vv
valuable [1] 122/15
value [4] 7/23 120/13
136/23 182/6
van [7] 57/5 89/6
94/12 96/5 99/8 172/2I
203/9
vaporised [2] 123/8
125/13
varied [1] 189/21
variety [1] 3/20
various [17] 3/22
8/10 13/6 17/4 33/4
65/18 65/22 66/3
66/15 68/4 69/7 69/9
72/10 75/6 77/12
82/25 90/21
Variously [1] 111/10
vary [1] 187/5
vassal [1] 178/19
vehicle [1] 141/19
veiled [2] 85/1 85/4
Vennells [17] 5/4
81/9 82/6 86/16 87/8
87/11 88/14 88/24
112/24 133/18 133/22!
134/1 134/8 134/23
136/9 161/23 171/12
verbal [1] 152/9
vernacular [1] 200/1
version [2] 39/19
45/24
versions [3] 8/10
33/4 33/6
very [92] 2/18 13/20
13/25 15/10 19/24
21/21 26/24 38/15
47/2 48/7 49/25 50/21
(86) transparent - very
Vv
Ww
very... [80] 53/20
63/16 64/6 65/1 66/16)
71/15 72/16 74/19
74/21 75/4 75/14
78/22 79/1 80/17 84/1
85/22 86/9 86/14
86/15 86/17 86/23
87/24 98/4 98/6 98/10)
98/22 100/10 105/9
108/14 108/16 108/19
109/18 110/13 114/5
114/6 115/2 116/6
116/7 116/13 116/16
117/2 118/15 122/14
122/15 126/4 131/4
135/4 135/24 135/25
137/2 137/23 138/7
138/20 142/22 155/13
157/10 159/21 162/12)
168/3 171/7 174/9
177/20 177/22 179/2
179/2 179/11 179/16
183/9 183/14 184/10
185/8 185/10 194/21
199/3 201/18 204/2
204/4 204/8 204/10
204/17
via [2] 42/11 142/20
view [50] 15/25 17/21
18/1 18/6 22/2 46/25
47/2 47/22 52/1 52/6
52/8 52/13 52/14
53/16 62/14 73/22
78/24 81/7 82/24 84/9
85/19 88/12 88/17
103/12 103/18 113/8
113/13 113/14 114/25
116/21 116/24 123/1
125/4 125/14 125/21
127/16 130/19 136/25
138/16 148/21 150/5
158/5 158/6 167/4
169/6 174/5 174/22
175/13 200/23 202/20
viewed [6] 73/10
92/20 150/22 159/5
177/6 200/5
viewing [1] 51/24
views [8] 30/13 58/20)
59/12 62/22 147/2
147/4 157/1 166/23
vigorously [1] 161/6
virtually [1] 8/11
vi ty [1] 20/18
Vision’ [1] 151/2
visit [2] 67/9 67/14
visited [1] 76/15
voice [2] 2/4 92/1
volume [2] 96/16
164/3
wagging [1] 92/25
wait [4] 117/2 175/22
186/9 192/18
Wales [3] 2/25 14/10
14/11
Walker [1] 92/6
want [15] 10/25 12/3
22/22 29/7 47/6 57/20
59/20 62/19 79/21
87/15 134/13 135/1
177/22 184/10 195/5
wanted [14] 7/4 7/20
10/23 28/11 44/25
47/9 67/13 87/8
101/20 113/12 127/24I
134/13 176/5 193/2
warfare [1] 201/1
Warmington [38]
3/22 4/21 5/9 6/23
8/17 8/23 41/24 41/25)
60/3 61/8 66/17 73/21
75/18 79/8 80/14
81/10 81/12 81/21
82/2 92/4 93/7 94/12
104/17 109/6 109/7
109/9 109/12 135/1
155/3 174/14 176/7
176/12 191/22 192/3
198/13 198/17 204/5
205/12
Warmington's [1]
102/12
warned [3] 84/21
115/2 129/18
was [786]
wasn't [34] 10/13
10/25 11/5 13/19
22/15 45/11 49/10
68/1 72/22 95/3
113/13 120/10 121/41
122/9 126/17 128/14
134/3 136/16 139/22
146/14 158/3 159/21
161/2 161/2 175/18
179/12 181/19 182/10)
182/23 183/23 183/24)
195/16 199/21 200/3
waste [2] 199/18
200/20
wasted [1] 199/16
waterfall [2] 117/14
184/23
way [44] 12/10 14/15
20/1 21/4 24/14 32/12
33/20 35/14 50/13
53/12 62/5 67/4 70/3
71/13 77/13 77/19
79/24 80/4 85/9 86/22
96/21 97/21 103/13
114/4 124/13 124/18
124/21 125/9 157/20
159/20 163/17 163/21
164/10 164/15 174/9
178/11 178/21 178/24
187/10 188/10 190/6
190/12 198/23 203/19I
we [516]
we'd [29] 6/13 6/14
8/25 9/1 57/16 57/22
59/9 63/11 85/18
90/14 102/5 121/11
125/13 126/8 128/12
129/11 129/12 131/10
131/23 132/1 133/4
134/10 136/4 159/23
160/25 164/4 164/19
199/17 202/22
we'll [17] 32/3 33/13
39/4 92/7 94/7 95/20
95/22 95/23 95/24
99/4 100/9 135/23
135/25 177/22 192/5
192/10 204/13
we're [19] 6/10 17/11
22/21 33/10 64/6 64/9
64/12 75/19 79/4
102/14 135/3 157/17
163/12 184/8 187/19
194/10 194/11 194/12]
194/12
we've [36] 8/16 26/5
36/5 36/13 36/18
39/10 44/23 46/11
46/15 49/11 50/13
55/19 55/19 59/1 62/3)
63/2 77/8 81/14 84/4
94/1 103/14 132/7
139/15 139/25 141/22
151/24 157/12 157/16
173/6 173/10 176/2
177/5 178/18 194/2
196/24 197/3
weakness [1] 89/17
Wednesday [1]
197/16
weeds [1] 121/23
week [2] 51/21
197/17
Weekly [4] 143/2
weeks [3] 22/18
179/23 195/11
welcome [1] 75/16
well [81] 3/9 4/4 12/2
12/16 14/10 16/1
20/16 25/4 26/2 26/15
37/1 49/15 50/11 54/5)
54/10 61/1 63/17 70/5)
72/6 80/8 95/1 103/14
106/19 114/5 114/16
116/10 117/8 119/12
119/15 120/22 122/5
124/1 125/9 126/17
127/3 127/20 129/10
134/6 135/22 136/16
137/16 137/23 137/25)
139/20 141/9 142/4
146/3 146/4 146/23
146/24 147/14 147/17)
153/24 160/3 162/11
167/21 168/13 169/19}
170/4 172/11 173/15
181/8 183/8 183/14
184/8 185/11 188/12
192/20 195/5 195/15
197/10 198/2 198/12
199/15 200/1 200/3
200/25 201/1 201/3
201/22 202/22
went [10] 9/4 45/8
79/4 79/9 118/12
124/8 129/15 174/24
189/24 203/18 180/25 181/7 184/19
were [294] 184/19 184/23 185/1
weren't [19] 7/24 185/4 185/10 185/24
47/14 48/3 54/2 56/16] 186/1 187/7 187/24
61/4 83/3 90/10 95/19
163/23 163/25 168/1
168/9 179/18 190/3
190/4 190/7 193/5
203/7
whammy [1] 182/19
what [198] 2/9 3/7
3/18 3/19 7/17 9/4
9/15 11/15 12/20 13/4)
16/9 16/11 17/7 19/9
21/2 22/5 23/25 26/18
27/20 28/12 32/14
34/15 35/19 36/5
38/23 39/10 40/5
41/20 44/12 44/14
44/23 47/25 49/23
49/24 50/12 55/23
57/2 57/20 59/3 59/9
61/8 61/18 62/13
62/20 63/22 67/6
67/14 67/19 68/1 68/1
68/7 70/6 70/11 70/24
72/18 72/20 72/24
73/14 73/17 73/17
74/3 74/20 75/2 75/4
75/7 75/21 77/1 77/7
79/22 80/18 80/18
80/21 81/13 82/3
82/11 84/22 85/16
85/21 87/8 87/11
88/24 89/15 91/2
92/22 92/23 93/6 94/9)
97/7 97/19 98/5 98/14
98/16 98/24 101/5
101/13 101/22 102/1
105/15 107/25 108/22)
114/5 114/14 114/14
115/4 115/25 116/3
116/9 116/13 117/5
119/1 119/5 119/18
120/11 121/18 121/22
122/3 123/24 124/3
124/17 127/1 128/15
129/13 130/2 130/2
131/10 131/11 134/13
134/20 135/11 136/10)
136/17 140/14 141/2
141/8 141/14 141/18
146/2 146/7 146/11
146/22 147/3 147/22
148/9 151/16 151/17
153/11 154/8 156/12
157/8 157/12 157/25
160/10 160/16 160/18)
160/25 163/1 163/21
166/18 166/20 167/2
167/12 167/17 170/1
170/11 173/16 174/5
174/12 175/14 175/15)
175/16 179/5 179/17
189/16 189/24 191/1
191/11 192/14 192/23)
193/11 193/12 193/21
194/9 196/14 200/11
202/22 203/2
what's [7] 79/23 96/7
100/20 103/12 136/10}
183/10 184/16
whatever [9] 10/22
100/2 112/21 113/11
135/6 136/13 141/12
183/22 185/3
whatsoever [1] 41/6
when [80] 19/22 20/9
21/8 21/18 23/16
23/19 23/22 24/2
27/15 27/17 28/2 29/4I
41/9 41/14 41/15 46/3
46/24 47/18 48/6
48/22 48/25 49/13
49/13 49/18 53/11
64/20 74/10 76/15
81/4 86/24 88/14 90/6
104/5 105/8 106/10
115/6 115/16 116/1
116/5 119/21 120/11
130/13 133/21 137/1
137/20 139/21 141/1
143/19 147/7 150/24
152/18 153/20 154/10}
154/18 163/16 168/11
168/14 169/8 171/12
175/10 175/10 175/19)
177/20 177/25 181/23}
184/11 189/12 192/7
193/13 194/9 196/11
197/9 198/3 200/10
200/12 200/14 200/22
200/23 202/12 202/15}
whenever [1] 141/10
where [29] 19/17
24/15 62/21 64/23
68/4 69/19 84/5 91/19I
92/20 93/25 103/22
1418/1 121/11 128/1
(87) very... - where
Ww
where... [15] 128/14
135/15 149/14 150/13)
161/7 169/9 175/25
176/3 184/13 187/12
187/20 191/4 191/14
193/2 193/12
where's [2] 146/9
164/17
whereas [5] 69/9
122/10 137/8 155/16
201/13
whereby [1] 93/23
wherever [1] 184/25
whether [46] 7/4 8/5
9/10 9/13 12/6 15/1
15/6 15/8 15/14 18/7
54/7 55/14 59/9 70/3
74/9 74/11 74/14
78/16 92/24 92/25
96/17 97/7 99/19
99/20 101/24 131/11
132/22 141/10 142/18
142/25 154/13 160/12)
160/24 163/11 165/4
169/1 171/13 176/20
180/11 186/6 187/25
189/17 197/4 199/11
199/13 201/19
which [137] 1/22
5/18 8/11 10/17 11/21
15/21 16/4 17/2 17/7
18/23 19/2 22/15
27/18 28/3 30/23
31/20 33/4 37/9 40/2
40/25 41/12 42/22
43/18 43/23 45/25
48/13 48/18 49/16
50/1 51/7 54/1 55/2
55/16 56/11 56/24
57/17 64/2 64/10 65/2
65/12 69/11 71/4
72/11 74/13 74/22
75/12 76/19 76/20
7712 77/14 78/8 78/9
78/25 82/22 83/25
84/10 84/17 84/18
85/3 88/20 91/16
91/21 93/12 94/3
98/21 100/24 101/16
104/19 105/2 107/24
109/19 109/23 110/7
111/1 113/19 116/20
117/3 117/11 117/13
117/21 118/8 122/12
122/22 124/9 124/19
124/21 125/10 125/11
125/16 125/24 126/11
126/24 127/6 127/7
128/23 129/4 132/6
133/5 137/14 139/19
143/23 144/17 145/7
145/14 145/16 145/18)
148/14 151/23 153/8
155/6 155/11 156/9
159/10 159/16 160/4
162/8 165/16 170/19
170/21 171/2 173/3
178/18 179/12 180/12)
181/9 181/18 181/23
193/10 195/2 196/23
197/2 199/1 199/12
200/7 201/9 201/19
203/3
while [4] 102/11
145/21 176/6 181/10
Whilst [2] 19/19 87/6
whistle [1] 91/3
whistleblowing [3]
90/20 177/7 178/12
whitewash [2]
179/15 179/19
who [49] 2/3 2/4
10/11 11/8 14/17
15/25 18/25 20/8
23/18 42/1 53/2 64/17
64/18 68/17 68/17
73/9 73/11 81/15
86/13 91/25 102/7
103/2 103/17 106/17
112/6 112/11 132/19
134/12 137/25 138/5
142/11 143/22 152/14)
152/23 155/23 166/13}
167/22 172/3 172/13
179/9 181/5 192/10
193/12 193/14 195/3
195/6 195/8 195/13
201/12
whoever [2] 165/19
174/11
whole [6] 16/3 125/3
157/15 179/6 183/20
184/9
wholly [2] 93/3
116/14
whom [8] 26/11
56/18 58/22 73/3
91/18 95/2 136/24
189/8
whose [2] 164/3
195/9
why [41] 10/13 11/4
11/16 20/15 33/5
40/22 41/8 41/10
42/24 60/23 62/17
67/13 75/9 94/24
106/23 114/3 114/14
124/15 126/16 127/19)
130/24 136/19 136/19)
137/20 141/24 145/23)
151/5 153/18 153/23
157/24 159/19 161/9
161/9 163/15 163/17
164/10 172/9 183/21
184/24 190/6 196/16
wide [9] 15/17 16/3
16/20 16/25 17/6
38/10 126/1 128/5
183/17
widely [4] 15/15
15/24 18/15 80/6
wider [4] 70/24 91/14
123/8 123/16
widespread [1] 150/8I
wife [1] 179/5
will [21] 8/22 30/4
41/5 42/13 60/13 98/2
98/3 103/1 107/25
146/10 149/7 151/4
154/19 157/18 162/3
174/25 175/1 183/4
184/21 185/5 188/19
Williams [13] 39/5
39/6 41/24 46/4 99/9
100/18 107/21 151/21
172/6 198/15 203/23
205/10 205/20
willing [4] 81/4
willingness [2] 81/2
149/3
windfall [1] 142/11
wire [1] 119/11
wise [1] 131/4
wish [13] 2/6 90/18
129/11 131/23 131/25}
144/25 164/7 171/6
171/11 171/23 171/24)
172/9 173/1
wished [5] 45/3
78/25 91/2 177/6
189/3
withheld [1] 43/2
withholding [2]
113/4 121/17
within [33] 14/15
17/19 20/13 21/24
25/13 43/9 50/12
57/19 64/17 77/15
80/7 86/25 91/6 96/14
98/4 99/5 101/14
103/21 112/11 115/8
115/12 118/2 118/3
128/16 145/23 150/23
163/15 169/2 181/8
182/21 186/25 188/10}
195/3
without [14] 9/12
9/20 14/1 17/20 41/6
65/23 70/1 119/1
119/24 125/19 142/6
167/15 179/1 180/4
withstood [1] 179/2
WITN00420100 [1]
17
WITNO01050100 [1]
109/16
WITN01050200 [3]
110/8 180/9 180/12
witness [91] 1/15
1/18 2/11 2/15 4/7 4/8}
4/11 4/19 10/16 12/13)
14/5 14/22 17/9 20/11
21/11 21/16 22/19
24/20 27/25 43/21
46/3 48/8 56/10 57/16)
65/11 68/7 68/9 69/4
70/13 71/18 72/1 74/7,
77/11 82/22 83/17
84/3 84/17 86/19 87/4
88/1 89/11 98/7 105/7,
105/18 105/20 105/21
106/2 106/17 107/8
108/18 110/6 110/10
4111/1 111/24 113/1
113/15 115/4 115/14
117/20 121/12 122/22
124/12 124/22 124/25}
132/4 137/11 145/5
155/4 165/24 166/4
166/7 166/15 166/22
167/10 167/12 167/14}
167/18 167/24 167/25)
168/3 169/10 169/13
169/15 171/3 172/8
175/7 178/1 178/2
193/6 195/23 204/8
witnesses [2] 93/23
131/18
Wolstenholme [2]
56/6 144/24
won't [2] 159/11
159/11
wonder [3] 154/13
154/16 180/10
word [14] 15/16
15/21 16/12 16/19
16/22 109/20 120/22
126/19 129/14 129/15)
131/23 147/20 204/6
204/7
worded [2] 163/17
164/10
Worden [1] 177/25
wording [2] 131/4
194/8
words [12] 8/22 16/3
89/5 97/23 121/4
123/11 132/1 152/19
159/12 165/18 182/22,
190/24
work [58] 2/1 4/16
10/3 11/1 11/7 11/10
13/15 18/5 18/19
19/22 20/9 47/8 60/18}
60/24 61/13 71/19
75/22 84/2 87/1 88/16)
90/7 91/4 91/23 97/19
110/20 112/10 113/23}
114/3 115/1 115/9
116/14 123/22 124/2
124/9 124/13 124/19
125/13 125/22 127/5
127/7 135/24 139/3
147/5 158/2 159/11
162/21 163/17 167/11
170/21 178/9 181/6
182/10 182/11 183/2
198/5 202/13 203/21
203/21
worked [9] 3/10 6/15
18/20 23/18 54/4
93/17 110/20 111/7
143/17
workers [1] 187/21
working [27] 17/19
21/18 25/9 25/9 25/18
29/25 42/11 43/5 43/7I
43/9 57/6 66/23 84/20)
85/6 85/12 86/1 87/15
87/17 87/18 87/21
92/17 105/10 139/19
153/7 153/25 180/20
198/6
workings [1] 148/3
workload [1] 148/13
workshop [3] 76/24
77/10 78/4
world [2] 131/19
173/20
world's [1] 173/19
worldwide [1] 3/5
worried [2] 86/6
190/7
worry [4] 48/21 59/2
183/3 190/6
worrying [1] 46/7
worse [3] 137/4
197/8 201/4
worst [2] 173/24
203/4
worth [2] 143/5 196/2
worthwhile [1] 9/14
worthy [4] 150/8
would [186] 5/5 5/18
6/4 6/11 6/15 7/13
8/11 9/12 9/14 10/22
10/22 11/21 12/9 12/9)
15/12 18/14 21/6 21/7)
25/1 27/19 29/21
29/24 31/15 31/16
32/24 37/3 37/9 38/8
42/23 42/23 49/3 52/3
56/12 60/6 60/19 63/6
63/18 67/6 68/21 70/8I
70/21 71/10 72/14
75/15 76/5 76/11
78/21 79/11 82/5
84/15 84/23 84/25
87/23 89/15 89/25
90/21 91/2 96/24
97/12 97/21 98/14
98/16 99/15 99/22
99/25 100/3 101/18
101/23 103/11 104/7
106/1 106/12 111/1
114/12 114/14 114/23)
114/23 116/6 117/11
118/2 118/3 119/7
(88) where... - would
Ww
would... [104] 119/19
119/20 120/6 121/22
123/3 123/10 123/13
123/16 127/5 129/12
129/18 131/8 134/9
135/2 135/19 136/2
137/3 137/17 138/22
139/19 139/20 140/16}
141/12 141/16 141/17)
141/24 142/9 142/14
142/19 142/19 143/8
143/13 143/18 146/4
147/3 147/9 150/15
156/1 156/21 158/24
159/4 159/6 160/22
161/24 162/16 165/10}
165/15 165/16 165/20
166/12 166/22 167/3
167/16 168/2 168/4
169/8 169/16 169/20
169/21 169/22 170/1
170/4 170/16 170/21
171/4 173/2 174/24
175/9 175/12 175/16
176/24 178/4 178/13
179/2 179/6 183/6
185/7 185/8 186/1
186/2 186/4 186/12
186/14 188/12 190/15
190/16 190/18 190/19}
192/4 193/8 194/19
194/20 195/3 195/5
195/13 196/10 197/23
199/15 199/16 199/24}
201/4 201/15 202/5
203/15
wouldn't [12] 5/8
6/17 7/22 9/19 61/24
126/19 134/22 164/20)
174/24 175/11 175/15
182/11
wound [1] 193/2
wrap [1] 99/16
write [1] 147/4
writes [1] 82/3
writing [4] 40/22 41/8)
41/10 120/24
written [8] 4/9 41/6
45/22 67/18 74/11
97/7 142/18 169/9
wrong [18] 72/20
97/13 120/16 124/17
124/24 141/15 142/12)
147/10 150/14 154/17)
157/17 158/17 163/12
165/18 165/21 183/11
193/17 201/18
wrongful [7] 60/15
60/25 61/6 162/5
164/2 164/9 165/5
wrongfully [3]
114/12 132/25 162/9
wrongly [1] 143/4
wrote [6] 93/7 128/25)
129/19 151/23 152/8
189/12
WYN [4] 107/21
198/15 205/10 205/20)
Wyn's [2] 102/17
173/1
X
XML [5] 77/25 78/5
78/8 78/21 78/22
XX [4] 101/11
Y
yeah [26] 49/9 50/16
55/13 76/16 77/12
80/15 82/1 85/12
94/15 107/6 117/23
124/24 141/21 148/6
153/14 155/5 161/13
161/21 176/8 177/4
177/15 180/7 188/12
192/15 194/14 197/1
year [12] 3/18 94/17
101/3 101/17 126/20
129/25 174/20 182/9
182/10 189/5 189/14
201/5
year-end [1] 201/5
years [18] 2/21 3/11
14/6 76/19 88/16
94/19 101/4 101/18
104/7 119/11 139/3
159/24 173/17 179/10)
179/21 189/6 189/18
189/24
years' [1] 115/1
yes [264]
yesterday [1] 80/9
yet [5] 119/16 121/1
154/2 158/9 203/14
you [798]
you'd [11] 6/17 60/21
62/14 91/18 109/17
141/21 171/6 185/12
185/15 186/23 192/16)
you'll [12] 5/3 8/15
8/22 30/11 31/24 44/7
68/10 76/8 95/23 99/6
100/10 184/21
you're [35] 2/24 25/7
26/7 27/22 41/23 55/8)
55/9 55/10 64/13 76/8
87/7 98/24 111/3
117/24 119/1 119/13
121/18 122/23 132/6
132/14 142/18 147/5
151/21 154/18 157/14)
159/13 161/23 165/17)
165/20 180/25 183/19)
184/19 194/9 196/5
200/11
you've [27] 2/14 18/9
26/18 36/13 52/17
69/13 74/14 77/10
80/18 91/8 98/15
104/24 109/13 110/2
115/14 116/10 118/23
147/8 152/19 158/12
176/16 180/14 180/14
183/21 187/12 196/16
197/7
young [6] 24/19 73/6
110/22 111/5 115/20
140/3
your [189] 1/11 1/20
2/2 2/14 2/16 2/19 3/2
4I7 4/8 4/19 10/3
10/15 11/2 12/13
13/47 14/5 14/12
14/22 15/9 15/25
16/12 16/17 17/9
17/13 18/19 18/21
20/11 21/11 21/24
22/2 22/19 27/2 27/13
27/16 28/14 34/8 35/2
35/16 35/20 38/21
38/25 39/9 39/25 40/6
40/9 40/20 41/11
44/17 41/20 42/1 42/7
42/8 43/21 45/13 46/3
46/16 46/21 47/9 48/8
49/10 50/14 53/15
53/20 56/12 57/16
59/12 60/21 60/24
61/22 62/18 63/6
65/11 68/9 69/4 69/12
69/25 70/13 71/11
72122 77/11 78/24
79/15 80/21 82/11
82/22 83/17 83/19
84/3 84/6 84/17 86/19
87/4 88/1 89/11 90/7
92/3 94/4 94/5 94/7
96/21 101/19 103/1
103/12 103/23 104/25I
105/12 107/5 107/13
108/15 109/11 109/25]
110/3 110/6 110/8
110/11 110/13 110/20
4114/4 111/24 112/10
112/18 113/1 113/15
114/25 115/4 115/14
115/15 115/17 116/20
117/20 119/3 120/19
122/22 123/19 123/24
124/12 124/22 125/20
126/24 127/16 132/4
133/17 133/19 134/21
137/11 139/3 140/10
144/4 145/9 147/2
147/3 147/6 150/5
154/8 154/9 155/4
156/8 157/5 160/12
160/18 160/19 162/17
164/11 165/24 166/5
166/15 169/17 170/14
171/2 171/3 171/6
174/6 175/6 177/10
177/12 177/16 180/8
183/5 185/1 185/4
186/1 186/11 188/13
189/2 190/24 195/18
197/8 199/9 204/11
yours [1] 29/1
yourself [1] 163/6
Yup [1] 140/21
r4
zero [3] 115/3 120/6
183/6
(89) would... - zero